Criminal Law

Defendant pled guilty but mentally ill to one count of first-degree murder and one count of robbery and was sentenced to prison terms of 90 years and 15 years, respectively. Defendant appealed from the denial of his motion to file a successive post-conviction petition challenging the constitutionality of the 90-year prison term on the basis that it violated the proportionate penalties clause of the Illinois Constitution. The appellate court affirmed the trial court. The Supreme Court granted defendant’s petition for leave to appeal and affirmed both the circuit and appellate court judgments, finding that defendant could not satisfy either prong of the cause-and-prejudice test where defendant’s intellectual disability did make him less culpable, but rather made him more likely to re-offend. (THEIS, NEVILLE, and HOLDER WHITE, concurring. CUNNINGHAM ROCHFORD and O’BRIEN took no part in the decision)

Defendant was found guilty of two counts of aggravated battery with a firearm and sentenced to consecutive 15 years terms. On direct appeal, defendant argued that the State failed to prove him guilty because the victim’s identification of him was unreliable and the remaining evidence was circumstantial, that the trial mistakenly believed defendant was eligible for extended-term sentencing, and that the trial court failed to inquire into defendant’s ineffective assistance of counsel claim pursuant to Krankel. The appellate court affirmed, finding that the trial court did not commit error. (CAVANAGH and DOHERTY, concurring)

Defendant appealed from the second-stage dismissal of his successive petition for post-conviction relief filed under the Post-Conviction Hearing Act. Defendant had raised four grounds for relief, including a claim of actual innocence based on newly discovered evidence in the form of an affidavit from a co-defendant stating that defendant was not involved in the crime that led to his convictions. The appellate court reversed and remanded for third-stage proceedings, finding that the defendant made a substantial showing of actual evidence. (ROCHFORD and MARTIN, concurring)

Appeal arising out of an order from the trial court requiring the Department of Corrections to pay attorney fees incurred by the respondent in proceedings under the Sexually Dangerous Persons Act. The DOC argued that under section 5 of the Act that the county was responsible for the respondent’s attorney’s fees. The appellate court reversed and remanded, finding that the plain language of the statute established that the cost of the respondent’s representation was the responsibility of the county and not the DOC. (HOLDRIDGE and BRENNAN, concurring)

Defendant was found guilty of being an armed habitual criminal and sentenced to nine years in prison. He challenged his conviction on direct appeal, alleging that the State failed to prove him guilty beyond a reasonable doubt, that the trial court committee multiple errors when responding to questions from the jury, and that the trial court erroneously barred testimony relating to the search warrant that led to defendant’s arrest. The appellate court was persuaded by defendant’s third argument and reversed and remanded, finding that absent the ability to introduce evidence that the warrant was targeting a different person, testimony about the warrant caused an inference of “predetermined guilt.” (PUCINSKI, concurring and COGHLAN, dissenting)