People v. Edwards, 2017 IL App (3d) 130190-B

Background

In July 2009, 17-year-old Matthew Edwards was arrested and taken voluntarily to a police station, where he gave a recorded confession implicating himself in a home invasion that resulted in one death and one attempted murder. He had a history of special-education placement, reading at roughly a 5th–6th grade level, and prior diagnoses (bipolar/mood disorder, ADD/ADHD) for which he was not medicated at the time.
Edwards moved to suppress his statement, arguing it was involuntary given his age, limited education/mental capacity, and that police did not allow him to contact his mother or another concerned adult; the trial court denied suppression after viewing the recorded interview and hearing testimony.
Defense sought a court-ordered fitness evaluation; the court signed an order (drafted by defense counsel) stating a bona fide doubt of fitness existed and ordered an evaluation; the appointed expert later reported Edwards was fit and sane.
The case proceeded to a stipulated bench trial; Edwards was convicted of first-degree murder and attempted murder; enhancement allegations that he personally discharged a firearm were proved; he received consecutive terms of 50 years (murder) and 40 years (attempted murder).
On appeal Edwards challenged (1) the denial of his suppression motion, (2) the trial court’s alleged failure to hold a statutorily required fitness hearing after finding a bona fide doubt, (3) that his aggregate 90-year sentence constituted an unconstitutional de facto life sentence under Miller v. Alabama, and (4) presentence incarceration credit. The appellate court affirmed as modified (awarding one additional day’s credit).

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Voluntariness of confession	State: totality shows confession voluntary; Edwards understood rights and voluntarily accompanied officers.	Edwards: confession involuntary due to age (17), low education/reading level, mental disorders, and denial of contact with a concerned adult.	Court: confession voluntary under totality; concerned-adult absence not dispositive; denial of suppression affirmed.
Fitness hearing after bona fide doubt order	State: grant of evaluation does not necessarily equal a court finding of bona fide doubt requiring a hearing.	Edwards: court’s written order finding a bona fide doubt required a statutory fitness hearing before proceeding.	Court: following Hanson, appointment of expert alone does not compel a fitness hearing; no plain-error shown; no hearing required.
Eighth Amendment challenge under Miller	State: Miller and related cases concern mandatory life without parole; Edwards got discretionary terms above the statutory minimum.	Edwards: mandatory minimums (totaling 76 years) create a de facto life sentence for a juvenile, unconstitutional under Miller.	Court: Edwards lacks standing to challenge mandatory minimum he did not receive; Miller inapplicable to discretionary sentence imposed; challenge rejected.
Presentence incarceration credit	State conceded error on credit calculation.	Edwards sought credit for day of arrest (July 7, 2009).	Court: grant one additional day of presentence credit (arrest day counts).

Key Cases Cited

Miller v. Alabama, 567 U.S. 460 (2012) (mandatory life-without-parole for juveniles unconstitutional)
In re Gault, 387 U.S. 1 (1967) (juvenile due-process protections; cautions about juvenile confessions)
People v. Hanson, 212 Ill. 2d 212 (2004) (ordering a fitness evaluation alone does not necessarily mean the court found a bona fide doubt requiring a fitness hearing)
People v. Westmorland, 372 Ill. App. 3d 868 (2007) (concerned-adult factor important where juvenile was intimidated and requests to contact parent were denied)
People v. Simmons, 60 Ill. 2d 173 (1975) (heightened caution required when obtaining confessions from juveniles)
People v. Prude, 66 Ill. 2d 470 (1977) (juvenile confessions are a sensitive concern requiring great care)