Illinois Appellate Court
Criminal Court
Post-Conviction Hearing Act
Sentencing
Defendant appealed the trial court’s denial of his motion for leave to file a successive post-conviction petition that argued his 48-year sentence for first-degree murder was unconstitutional because he was 18 years old at the time of the offense. The appellate court affirmed, finding that defendant waived all non-jurisdictional errors, including constitutional errors, when he entered a voluntary plea of guilty. (HOWSE and BURKE, concurring)