People v. Brown

Defendant received a mandatory natural life sentence after he committed a third Class X felony. The supreme court considered the question of whether a 2021 amendment to the Unified Code of Corrections, which established that a life sentence is only mandatory if the defendant’s first Class X felony occurred when the defendant was 21 years old or older, was a retroactive amendment to or a clarification of the version of the prior version of the statute. Defendant had been sentenced prior to the amendment and was 17 years old at the time of his first offense. The supreme court held that the 2021 amendment did not apply retroactively to the defendant’s sentence and did not clarify the law as it existed at the time of his sentencing. (THEIS, HOLDER WHITE, CUNNINGHAM, and ROCHFORD, concurring and OVERSTREET and O’BRIEN, specially concurring)