Illinois Appellate Court
Criminal Court
Post-Conviction Hearing Act
Defendant appealed from an order dismissing his amended successive Post-Conviction Hearing Act petition for relief from his first-degree murder conviction. Defendant argued that he did not receive reasonable assistance from post-conviction counsel because counsel did not argue that defendant’s sentence violated the proportionate penalties clause of the Illinois constitution. The appellate court affirmed, finding that defendant did not identify a meritorious basis for a proportionate-penalties claim where he did not establish that his sentence was a de facto life sentence. (McLAREN and JORGENSEN, concurring)