People v. Miller

202 Ill. 2d 328 (Ill. 2002) · Supreme Court of Illinois · November 21, 2002 · No. No. 89795

Summary

The Supreme Court of Illinois held that applying the multiple-murder sentencing statute to a 15-year-old juvenile convicted under a theory of accountability violated the proportionate penalties clause of the Illinois Constitution. The court affirmed the trial court's sentence of 50 years' imprisonment rather than mandatory natural life imprisonment without parole. The court also addressed its jurisdiction to review the State's direct appeal from the trial court's constitutional ruling.

Holdings

  1. Supreme Court Rule 603 provides an independent basis for the Illinois Supreme Court to review a circuit court's declaration that a statute is unconstitutional in a criminal case, and the court therefore had jurisdiction over the State's direct appeal.
  2. The multiple-murder sentencing statute, as applied to Miller—a 15-year-old juvenile convicted under an accountability theory and serving as a lookout—violated the proportionate penalties clause of the Illinois Constitution because mandatory natural-life imprisonment without parole was unconstitutionally disproportionate.

Questions Presented

  1. Whether the Illinois Supreme Court had jurisdiction over the State's direct criminal appeal from the circuit court's finding that the sentencing statute was unconstitutional.
  2. Whether mandatory natural-life imprisonment under the multiple-murder sentencing statute was unconstitutional as applied to a 15-year-old juvenile convicted under an accountability theory for acting as a lookout.

Disposition

affirmed

Cases Cited (24)

  • People v. Truitt, 175 Ill. 2d 148, 151, 676 N.E.2d 665 (1997)(limited)
  • People v. Wooters, 188 Ill. 2d 500, 504, 722 N.E.2d 1102 (1999)(followed)
  • People v. Young, 82 Ill. 2d 234, 246-47, 412 N.E.2d 501 (1980)(followed)
  • People v. Davis, 177 Ill. 2d 495, 501-04, 687 N.E.2d 24 (1997)(followed)
  • People v. Malchow, 193 Ill. 2d 413, 418, 739 N.E.2d 433 (2000)(followed)
  • People v. Taylor, 102 Ill. 2d 201, 204-08, 464 N.E.2d 1059 (1984)(distinguished)
  • People v. Cooks, 271 Ill. App. 3d 25, 35-42, 648 N.E.2d 190 (1995)(distinguished)
  • People v. Wages, 261 Ill. App. 3d 576, 589, 633 N.E.2d 855 (1994)(distinguished)
  • People v. Rice, 257 Ill. App. 3d 220, 228-29, 628 N.E.2d 837 (1993)(distinguished)
  • People v. Rodriguez, 134 Ill. App. 3d 582, 593, 480 N.E.2d 1147 (1985)(distinguished)

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