Illinois Appellate Court Grants Motion for 19-Year-Old Given De Facto Life Sentence to File Successive Postconviction Petition
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
On December 4, 2020, an Illinois State appellate court reversed a lower court’s decision and granted defendant Jessie Williams’ motion to file a postconviction petition challenging his 43-year prison sentence for felony murder and armed robbery, which he committed at age 19.
Williams asserted that his 43-year sentence was a de facto life sentence and thus violated the Illinois state constitution. The Illinois Supreme Court has previously held that the ruling in Miller v. Alabama, a 2005 U.S. Supreme Court case which prohibited mandatory life sentences for homicide offenders under the age of 18, also applies to discretionary and de facto life sentences. The Illinois Supreme Court then determined that a de facto life sentence is any sentence exceeding 40 years for a juvenile offender. Williams argued that because he was 19 years old at the time of the offense, and because his personal background showed rehabilitative potential, the rulings of Miller and its progeny should be applied to his case.
Several recent cases in Illinois have addressed this extension of Miller, but none has explicitly extended Miller to young adults. For example, in one recent case, People v. Ruiz, 2020 IL App (1st) 163145, the court stated that “young adult defendants are not entitled to a presumption that Miller applies to them.” However, several cases, including Ruiz, have indicated that a postconviction proceeding would be the proper place to address the issue. In People v. Harris, 2018 IL 121932, the Illinois Supreme Court stated that a young adult defendant must show “how the evolving science on maturity and brain development that helped form the basis for the Miller decision applies to defendant’s specific facts and circumstances.”
Record evidence showed that Williams grew up in a Chicago neighborhood that he described as “a drug and gang infested hell.” He described himself as an excellent student involved in several extracurricular activities, and his mother described him as an “excellent man” that “got caught up with the wrong crowd.”
The appeallate court found that Williams “presented a prima facie claim that he was a highly intelligent and successful student until his senior year of high school, regrettably entered a transitory phase as a young adult and made some poor, immature choices, but nevertheless retained significant rehabilitative potential.” Because of these mitigating factors, as well as Williams’ potential for rehabilitation, the court reversed the lower court’s denial and granted Williams’ motion to file a postconviction petition.
Citation: People v. Williams, 2020 IL App (1st) 190387-U
Key words: LWOP, Miller v. Alabama, Illinois, de facto life sentence, young adult, adolescent brain
This post is the 78th 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.