Illinois Appellate Court Denies Leave to File Postconviction Petition Because Petitioner Provided Only General Research on Young Adult Brain Development
Recent Cases in Law and Neuroscience, Curated by the Center for Law, Brain & Behavior and the Shen Neurolaw Lab with support from the Dana Foundation
An Illinois appellate court affirmed the 53-year sentence of Joseph Eastling on December 11, 2020, rejecting Eastling’s claim that his sentence is an unconstitutional de facto life sentence because he was 18 years old at the time of his crime. This case is one of many challenging life sentences or de facto life sentences for young adults in Illinois, which have so far had mixed results, though several young adult defendants have been granted leave to file postconviction petitions.
In September 2000, Eastling and his co-defendant shot and killed Charles Fowler and injured Michael Caisel during an altercation at Fowler’s home. Eastling and his co-defendant were each convicted of first-degree murder and attempted first-degree murder and sentenced to an aggregate 53 years. Eastling’s conviction was affirmed by the appellate court. Eastling then filed a motion for leave to file a successive postconviction petition in 2018, which was denied. Eastling appealed this decision.
In his motion, Eastling contended that his sentence was an unconstitutional de facto life sentence based on the decision in Miller v. Alabama, prohibiting mandatory life without the possibility of parole (LWOP) sentences for juveniles, and Miller’s progeny, including Illinois state decisions prohibiting discretionary and de facto LWOP for juveniles. Eastling “noted that he was sentenced as an 18-year-old young adult and argued that new research in neurobiology and developmental psychology ‘proves’ that brain development as the time of the offense was ‘closer to adolescents than it was to an adult.’” He argued that because young adult brains are “not more developed than a juvenile’s,” the protections in Miller and its progeny should apply to him, and that his sentence violated both the proportionate penalties clause of the Illinois Constitution and the Eighth Amendment of the United States Constitution.
On appeal, the appellate court found that Miller explicitly drew the line at age 18 under the U.S. Constitution and that Eastling’s “apparent wish to redraw that line is a task for the legislature.”
Regarding his Illinois state constitutional claim, the appellate court noted that in previous cases such as People v. Harris, 2018 IL 121932, the court had found that young adults could potentially raise this claim in a postconviction petition and granted leave to do so. However, the court found that “there is nothing to indicate how [Eastling’s] own immaturity or individual circumstances would provide a compelling reason to allow him to file a successive postconviction petition.” The court further noted that Eastling’s “recitation of various studies regarding the evolving science of juvenile maturity and development is insufficient to survive the more exacting standard that would warrant the filing of a successive postconviction petition.”
The court found that “to obtain leave to file a successive petition, a petitioner provide some evidence or documentation demonstrating that the petitioner’s brain development was delayed.” Because Eastling “provided only general studies that the typical young adult’s brain (but not necessarily his) is not much more developed than a typical juvenile’s”, he did not fulfill this requirement.
Accordingly, the appellate court affirmed the judgement of the circuit court to deny Eastling’s motion for leave to file a successive postconviction petition based on his claims.
Citation: People v. Eastling, 2020 IL App (1st) 191206-U
Key words: Illinois, Miller v. Alabama, de facto life sentence, young adult, adolescent brain, LWOP
This post is the 72nd post as part of an ongoing Center for Law, Brain & Behavior (CLBB) series tracking the latest developments in law and neuroscience cases. To see previous posts about recent cases, see the full case archive on the CLBB website. To see updates on legal scholarship, see the Neurolaw News, hosted by the MacArthur Foundation Research Network on Law and Neuroscience. This project is made possible through support of the Dana Foundation.
