People v. Holman

This case presents question as to whether trial court properly denied defendant’s petition for leave to file successive post-conviction petition, alleging that his natural-life sentence violated 8^th Amendment because he had committed murder of 83-year-old victim when he was 17 year-old minor. Appellate Court, in affirming instant denial, found that: (1) sentence of natural-life might still be appropriate where, as here, trial court had discretion to consider other sentences; and (2) defendant’s sentencing hearing comported with dictates of Miller, 132 S.Ct. 2455, that included arguments by defense counsel to have trial court consider defendant’s youth when imposing sentence. Moreover, trial court could properly have found that defendant presented no rehabilitative potential given his three murders over three-month period of time and his lack of remorse. Ct. rejected defendant’s request to extend Miller holding of categorical bar on mandatory natural-life sentences for juveniles to instant case concerning discretionary natural-life sentence for crimes committed by juveniles.