Illinois Appellate Court
Criminal Court
Post-Conviction Hearing Act
Defendant was convicted of first-degree murder and sentenced to 53 years in prison. The trial court denied defendant’s petition to file a successive pro se post-conviction petition arguing that his sentence violated the proportionate penalties clause because he was 20 years old at the time of the offense. The appellate court affirmed, finding that defendant did not establish cause under the cause and prejudice test for filing a successive post-conviction petition. (McBRIDE and ELLIS, concurring)