People v. Craighead

Defendant, age 16 at time of offense, was convicted of 1997 murders of two persons, after being tried as an adult. Court sentenced Defendant to natural life, pursuant to provision requiring mandatory natural life for any defendant, regardless of age at time of offense, found guilty of murdering more than one person. Lack of culpable negligence excused Defendant's 7-month delay in filing postconviction petition, and significant changes in state and federal law affected Defendant's initial petition, which remained pending in trial court for nearly 10 years. U.S. Supreme Court's 2012 decision in Miller v. Alabama, which holds that mandatory imposition of life sentence without parole on a person under age 18 at time of offense violates 8th amendment prohibition against cruel and unusual punishment, applies retroactively to cases on collateral review. (WELCH and CHAPMAN, concurring.)