People v. Croom
2012 IL App (4th) 100932
Ill. App. Ct.2012Background
- Defendant, age 16, charged with first-degree murder for death of 3-year-old Altravius Bolden (June 2004).
- Pretrial suppression motion contended statements to Detective Rea in a van were involuntary and obtained during custodial interrogation without proper Miranda waiver.
- Defendant was found unfit to stand trial in Sept. 2005; restored to fitness in Mar. 2006.
- Trial in Sept 2006 led to a guilty verdict; sentencing followed in Oct 2006 to 50 years’ imprisonment.
- On direct appeal, convictions were affirmed in Feb. 2008; later, in Nov. 2008, defendant’s postconviction petition was filed; leave to file a successive postconviction petition was denied in Oct. 2010; issue on appeal centered on the automatic transfer provision of the Illinois Juvenile Court Act and on cause-and-prejudice for successive petitions.
- Court ultimately held the automatic transfer provision did not violate due process and that leave to file a successive postconviction petition was properly denied; the State’s costs on appeal were awarded
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the automatic transfer provision violates due process. | Croom argues substantive and procedural due process violations from automatic transfer. | The State contends transfer is rationally based and constitutional. | No due process violation; provision sustained. |
| Whether defendant showed cause and prejudice to file a successive postconviction petition. | Croom claims prison lockdown and lack of access to fitness documents blocked initial filing. | State argues lack of objective external factor and lack of prejudice. | Failed cause-and-prejudice show; leave denied. |
| Whether Kent v. United States requires a different result for procedural due process. | Defendant relies on Kent to claim adjudicative discretion violated due process. | State asserts Kent does not apply to automatic transfer. | Kent does not render the statute unconstitutional. |
| Whether J.S. and later cases support revisiting transfer rationale in light of Roper/Graham. | Croom urges revisiting rational basis due to Eighth Amendment decisions. | State argues Roper/Graham do not apply to due-process challenge here. | Roper/Graham do not undermine due-process analysis of automatic transfer. |
| Whether the rule 19 notice issue affects forfeiture of the claim. | Rule 19 notice satisfied; issue preserved. | Not necessary to reach merits because due process nonviolation. | Notice sufficient; merits reachability unaltered. |
Key Cases Cited
- People v. J.S., 103 Ill. 2d 395 (Ill. 1984) (automatic transfer rational basis upheld for 15–16-year-olds in enumerated offenses)
- People v. M.A., 124 Ill. 2d 135 (Ill. 1988) (further support for automatic transfer constitutionality)
- Kent v. United States, 383 U.S. 541 (U.S. 1966) (procedural due process concerns for juvenile transfers; Kent distinguished)