Defendant, age 16 at time of offenses (in 1999), entered a fully negotiated guilty plea at age 17, pleading guilty to 1 count each of 1st degree murder and residential burglary and 2 counts of armed robbery in exchange for State dismissing remaining numerous serious charges. He was sentenced to 50 years. No one can be certain of outcome of case if Defendant had chosen to proceed to trial. It is speculative to conclude that Defendant was doomed to be convicted of the most serious charges and to be sentenced to mandatory life without parole. Defendant's knowing and voluntary guilty plea waived any constitutional challenge based on subsequent changes in the applicable law. As the trial court had the option to accept or reject the plea agreement, its decision was an exercise of its discretion. Thus, Miller v. Alabama is inapplicable, and it was not error to deny Defendant's motion for leave to file successive postconviction petition. (GARMAN, THEIS, M. BURKE, and OVERSTREET, concurring; NEVILLE and A. BURKE, dissenting.)
Illinois Supreme Court
Criminal Court
Juvenile Sentencing