People v. Coty
2020 IL 123972
| Ill. | 2020Background
- William Coty, an intellectually disabled adult, was convicted of multiple sexual offenses against a six‑year‑old and, because of a prior aggravated criminal sexual assault conviction, was originally sentenced under the statute to mandatory natural life imprisonment.
- Coty filed a 2‑1401 petition claiming the mandatory‑life statute was unconstitutional (as‑applied and facially) under Illinois’s proportionate penalties clause and the Eighth Amendment because it barred consideration of his intellectual disability.
- The appellate court vacated the 1st sentence, remanded for resentencing, and on resentencing the circuit court imposed a 50‑year (extended‑term) sentence to be served at 85%; Coty appealed that sentence as a de facto life term improperly imposed without adequate consideration of his disability.
- A later precedential appellate opinion vacated the 50‑year sentence as a de facto life term and ordered a new sentencing, relying on Atkins and Miller principles and criticizing the absence of updated evidence about Coty’s disability and risk.
- The Illinois Supreme Court reversed the appellate court: it held the mandatory natural life statute was constitutional as applied to Coty, rejected extension of Atkins/Miller to bar life or de facto life sentences for intellectually disabled adults, rejected Coty’s Eighth Amendment and proportionate‑penalties claims, and allowed the 50‑year de facto life sentence to remain.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether mandatory natural‑life sentence (repeat child sex offender statute) is unconstitutional as‑applied under Illinois proportionate penalties clause | Statute is a constitutional legislative determination to protect children; mandatory life is permissible for repeat offenders | Statute barred consideration of his intellectual disability and was disproportionate as‑applied | Held constitutional as‑applied; original mandatory life was not clearly excessive; appellate court erred to vacate on that ground |
| Whether resentencing court’s 50‑year term was a de facto life sentence requiring Atkins/Miller safeguards | State: resentencing court considered the record and disability evidence; no special procedural rule required | Coty: 50 years is de facto life for him and required individualized consideration of Atkins factors; sentencing was deficient | Held: appellate court erred to require Atkins/Miller procedural safeguards here; circuit court did not abuse discretion; 50‑year term may stand |
| Whether Atkins/Miller (and progeny) must be extended to prohibit life or de facto‑life sentences for intellectually disabled adults | State: Atkins confined to capital cases; Miller is juvenile‑specific; no extension warranted | Coty: Atkins/Miller principles require individualized consideration before imposing life/de facto life on intellectually disabled adults | Held: refused to extend Atkins/Miller to bar life/de facto life sentences for intellectually disabled adults; no new individualized‑sentencing rule imposed |
| Eighth Amendment challenge to the 50‑year/de facto life sentence | State: Illinois proportionate‑penalties analysis dispositive; national standards not to extend Atkins/Miller | Coty: sentence cruel and unusual under the Eighth Amendment | Held: Eighth Amendment claim rejected; proportionate‑penalties analysis controls and fails to invalidate sentence |
Key Cases Cited
- Atkins v. Virginia, 536 U.S. 304 (2002) (intellectually disabled offenders have diminished culpability; death penalty unconstitutional in such cases)
- Miller v. Alabama, 567 U.S. 460 (2012) (mandatory life without parole for juveniles unconstitutional; individualized consideration required for juveniles)
- People v. Huddleston, 212 Ill. 2d 107 (2004) (upheld Illinois mandatory natural‑life statute as applied; legislative interest in preventing recidivism of sex offenders)
- People v. Heider, 231 Ill. 2d 1 (2008) (intellectual disability is a mitigating factor but may support a sentence enhancement when it evidences future dangerousness)
- Harmelin v. Michigan, 501 U.S. 957 (1991) (upheld mandatory life for certain adult crimes; distinction between capital and noncapital sentencing)
- Graham v. Florida, 560 U.S. 48 (2010) (life without parole for juveniles in nonhomicide cases unconstitutional; relied on proportionality and evolving standards)
- Heller v. Doe, 509 U.S. 312 (1993) (mental retardation is a relatively permanent condition; dangerousness may be assessed from adult records)