People v. Coty
2018 IL App (1st) 162383
Ill. App. Ct.2018Background
- William Coty, an intellectually disabled adult (IQ ~55–65), was convicted of predatory criminal sexual assault of a minor; a prior aggravated-sexual-assault conviction exposed him to mandatory natural life at original sentencing.
- On direct appeal his conviction was affirmed; Coty later filed a section 2-1401 petition challenging the mandatory natural-life sentence as unconstitutional because the statute prevented consideration of his disability.
- This court in a prior opinion (Coty II) held the mandatory natural-life scheme was unconstitutional as applied to Coty under Illinois’ proportionate-penalties clause and remanded for resentencing to allow a term-of-years.
- On remand (2016) the trial court, after brief argument and review of the trial record and a new PSI (which contained no updated mental-health evaluation), sentenced Coty (then 52) to 50 years (85%); with credit the earliest release would be age ~84, actual discharge ~88.
- Coty appealed the 50-year sentence, arguing (1) trial court abused discretion by imposing a de facto life term without properly treating it as such, and (2) the de facto life term is unconstitutional as applied under the Eighth Amendment and Illinois’ proportionate-penalties clause because the court failed to consider attendant characteristics of intellectual disability.
Issues
| Issue | People’s Argument | Coty’s Argument | Held |
|---|---|---|---|
| Whether resentencing court abused its discretion by imposing a 50‑year term | Resentencing court complied with remand and stayed within statutory range; no abuse | 50 years is a de facto life term for Coty and court failed to treat it as such | No abuse of discretion under appellate standard—the court did what the remand directed, considered record and arguments |
| Whether a 50‑year term imposed on Coty constitutes a de facto life sentence | 50 years is within statutory extended range and lawful | The sentence is functionally unsurvivable and thus a de facto life term equivalent to natural life | The 50‑year term is a de facto life sentence given Coty’s age and prison life-expectancy analyses |
| Whether imposing a discretionary de facto life sentence without considering attendant characteristics of intellectual disability violates Illinois’ proportionate‑penalties clause | Court followed remand and considered existing record; constitutional claim forfeited or not proven | Court failed to consider up-to-date evidence of Coty’s intellectual disability and attendant characteristics; thus sentence is disproportionate | Vacated: under Illinois constitution the court must consider attendant characteristics of intellectual disability (paralleling Miller/Atkins lines); sentence violated proportionate‑penalties clause and must be vacated and remanded for new sentencing before a different judge |
| Whether Eighth Amendment protections require the same procedural safeguards (Miller line) for intellectually disabled adults facing de facto life terms | Eighth Amendment challenge not preserved (but State urged merits may be addressed) | De facto life sentences for intellectually disabled adults should be subject to Miller‑style individualized consideration | Court relied principally on state proportionate‑penalties clause; extended Miller/Atkins rationale to intellectually disabled adults and held procedural safeguards apply in this context (constitutional error found under state clause) |
Key Cases Cited
- Atkins v. Virginia, 536 U.S. 304 (clinical features of intellectual disability reduce culpability)
- Miller v. Alabama, 567 U.S. 460 (mandatory life‑without‑parole for juveniles requires individualized sentencing consideration)
- Graham v. Florida, 560 U.S. 48 (bars life‑without‑parole for juveniles in nonhomicide cases)
- Roper v. Simmons, 543 U.S. 551 (death penalty unconstitutional for juveniles)
- Montgomery v. Louisiana, 136 S. Ct. 718 (Miller retroactivity and requirement of individualized sentencing)
- People v. Reyes, 2016 IL 119271 (de facto life terms for juveniles require Miller‑style consideration)
- People v. Holman, 2017 IL 120655 (Miller applies to discretionary as well as mandatory life sentences for juveniles)
- People v. Miller (Leon Miller), 202 Ill. 2d 328 (Illinois proportionate‑penalties clause context and rehabilitative objective)