People v. Holman
2017 Ill. LEXIS 669
| Ill. | 2017Background
- In 1979 Richard Holman, age 17, was convicted of first-degree murder for the killing of an elderly woman and sentenced to natural life imprisonment without parole after a joint trial with co-defendant Girvies Davis.
- The presentence investigation (PSI) and psychological reports documented Holman’s limited education, borderline/mildly retarded IQ scores, a childhood head injury, susceptibility to peer influence, and a probation officer’s conclusion that he lacked remorse and had poor rehabilitation prospects; Holman declined to present mitigating evidence at sentencing.
- Holman did not challenge his sentence on direct appeal; he later filed multiple postconviction and collateral petitions. In 2010 he sought leave to file a successive postconviction petition raising, among other claims, that his life-without-parole sentence was unconstitutional under Roper/Graham/Miller.
- After this court’s decisions in Davis and Montgomery addressing Miller’s retroactivity and scope, the appellate court on remand found the original sentencing complied with Miller because the trial court considered relevant youth-related evidence in the record; the appellate decision was affirmed by the Illinois Supreme Court.
- The Supreme Court of Illinois held (1) Miller applies to discretionary life-without-parole sentences for juveniles, (2) trial courts must consider the Miller factors when a juvenile faces life without parole, but (3) Holman’s original sentencing hearing sufficiently considered his youth-related characteristics, so no new sentencing was required.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does Miller apply only to mandatory life-without-parole sentences or also to discretionary life-without-parole sentences for juveniles? | State: Miller limited to mandatory schemes; discretionary sentences unaffected. | Holman: Miller’s reasoning about diminished culpability applies to discretionary life sentences too. | Miller applies to discretionary juvenile life-without-parole sentences; sentencers must consider youth and attendant characteristics. |
| What process must courts follow under Miller/Montgomery when a juvenile received life without parole? | State: Courts need only consider youth generally; no specific factor list mandated. | Holman: Trial courts must consider the specific Miller-listed youth-related characteristics. | Trial courts must consider Miller factors (age/immaturity, family/home, participation/peer pressure, competence, rehabilitation prospects); those factors are not exhaustive. |
| Did Holman forfeit his as-applied Miller claim by not raising it earlier in postconviction proceedings? | State: Holman forfeited the claim by failing to raise it earlier and in successive-petition procedures. | Holman: Claim may be reviewed here given Davis guidance and fully developed record. | Court reached the merits (declining to enforce forfeiture here) because the record was sufficiently developed. |
| Did Holman’s original sentencing comply with Miller (i.e., did the court consider youth and attendant characteristics)? | State: Trial court considered the PSI, psychological reports, trial evidence, and counsel’s arguments showing youth-related evidence was before the court. | Holman: Trial court stated it found no mitigating factors and thus failed to consider youth-related mitigation. | The sentencing court did consider youth-related evidence in the record; Holman voluntarily presented no mitigating proof; sentence upheld. |
Key Cases Cited
- Miller v. Alabama, 567 U.S. 460 (Juvenile life-without-parole requires consideration of youth and attendant characteristics)
- Montgomery v. Louisiana, 577 U.S. 190 (Miller applies retroactively; sentencing courts must consider youth before imposing life without parole)
- Graham v. Florida, 560 U.S. 48 (Eighth Amendment bars life without parole for nonhomicide juvenile offenses)
- Roper v. Simmons, 543 U.S. 551 (Eighth Amendment bars capital punishment for juveniles)
- People v. Davis, 2014 IL 115595 (Illinois: Miller’s holding and retroactivity context)
- People v. Thompson, 2015 IL 118151 (As-applied vs facial challenges and need for developed record)