Defendant pled guilty but mentally ill to one count of first-degree murder and one count of robbery and was sentenced to prison terms of 90 years and 15 years, respectively. Defendant appealed from the denial of his motion to file a successive post-conviction petition challenging the constitutionality of the 90-year prison term on the basis that it violated the proportionate penalties clause of the Illinois Constitution. The appellate court affirmed the trial court. The Supreme Court granted defendant’s petition for leave to appeal and affirmed both the circuit and appellate court judgments, finding that defendant could not satisfy either prong of the cause-and-prejudice test where defendant’s intellectual disability did make him less culpable, but rather made him more likely to re-offend. (THEIS, NEVILLE, and HOLDER WHITE, concurring. CUNNINGHAM ROCHFORD and O’BRIEN took no part in the decision)
Illinois Supreme Court
Criminal Court
Post-Conviction Hearing Act