People v. Davis
2014 IL 115595
| Ill. | 2014Background
- Davis, a juvenile, was sentenced in 1993 to natural life imprisonment without parole for two murders and related crimes.
- He challenged the legality of his life-without-parole sentence via a postconviction petition and transfer on collateral review.
- Appellate and circuit courts vacated or remanded based on Miller v. Alabama and juvenile culpability.
- Miller held that mandatory life-without-parole for juveniles is unconstitutional and requires individualized sentencing.
- Illinois argued Miller is not retroactive or facially unconstitutional in this case.
- Court holds Miller applies retroactively as a substantive rule and that the preexisting statutory scheme allowed consideration of age at a new sentencing hearing, remanding for a new sentencing hearing.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Miller applies retroactively to Davis on collateral review | Davis argues Miller is retroactive and requires resentencing | State contends Miller is not retroactive under Teague framework | Miller applies retroactively as a new substantive rule |
| Whether the statute imposing mandatory life without parole for multiple murders is facially unconstitutional | Davis contends Miller voids the statute as applied to juveniles | State argues statute remains valid for adults and not facially unconstitutional | Statute not facially unconstitutional; Miller applies to juveniles only |
| Whether Davis’ juvenile transfer and related counsel issues warrant relief | Ineffective assistance at transfer hearing due to failure to interview eyewitness | Procedural default bars successive petitions; evidence could have been discovered earlier | Claim barred; no cause for failure to raise earlier; petition denied on this ground |
| Whether Davis is entitled to relief under the Illinois Constitution | Graham and Miller require a different assessment of juvenile culpability | Constitutional arguments previously rejected; res judicata applies | Illinois Constitution claims rejected; Miller applied to remand for resentencing |
| Whether Davis may be resentenced with discretion to consider all permissible penalties | New sentencing hearing allows non-mandatory options | Remand unnecessary if Miller retroaction does not apply | Remand for a new sentencing hearing to consider all permissible sentences |
Key Cases Cited
- Miller v. Alabama, 567 U.S. 460 (2012) (mandatory life without parole for juveniles violates Eighth Amendment; requires sentencing discretion)
- Graham v. Florida, 560 U.S. 48 (2010) (life without parole for non-homicide juvenile cases unconstitutional; need chance for release)
- Roper v. Simmons, 543 U.S. 551 (2005) (juvenile defendants have diminished culpability; prohibition on death penalty for under 18)
- Teague v. Lane, 489 U.S. 288 (1989) (establishes retroactivity framework for new constitutional rules on collateral review)
- Schriro v. Summerlin, 542 U.S. 348 (2004) (substantive vs. procedural retroactivity distinction for new rules)