Illinois Appellate Court
Criminal Court
Post-Conviction Hearing Act
Defendant was found guilty of first-degree murder and sentenced to a total of 60 years in prison, including a mandatory firearm enhancement. Defendant, who was 20 years old at the time of the offense, filed a motion for leave to file a successive post-conviction petition arguing that his sentence violated the proportionate penalties clause. The trial court denied his motion and defendant appealed. The appellate court affirmed, finding that defendant failed to establish a prima facie case of both cause and prejudice for a youth-based proportionate penalties claim. (LANNERD and KNECHT, concurring)