People v. Holman, 2017 IL 120655

Background

In 1979 Richard Holman (age 17 at offense) was convicted of first‑degree murder for the killing of an elderly woman and later sentenced to life without parole; he had prior juvenile adjudications and concurrent adult convictions for other murders.
The presentence investigation and psychological reports documented borderline/mildly retarded IQ, possible organic brain injury, a history of peer influence, family circumstances, and the probation officer’s view that Holman lacked remorse and rehabilitative prospects.
At sentencing Holman and his mother declined to present mitigating evidence; counsel made a general plea for consideration of rehabilitation but offered no proof; the trial court stated it considered the PSI, trial evidence, and arguments and found no mitigating statutory factors and many aggravating factors, concluding Holman was not rehabilitatable.
Holman did not challenge his life sentence on direct appeal; he later filed multiple postconviction and collateral petitions, culminating in a successive postconviction petition asserting Miller v. Alabama claims (and other Eighth Amendment arguments).
The Illinois appellate court held Holman’s sentencing complied with Miller; the Illinois Supreme Court granted review to decide whether Miller/Montgomery require consideration of youth factors for discretionary life without parole and whether Holman was entitled to relief.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does Miller apply to discretionary life without parole sentences for juveniles?	State: Miller applies only to mandatory life sentences.	Holman: Miller's logic extends to discretionary LWOP; youth must be considered before any LWOP.	Miller applies to discretionary juvenile LWOP; sentencing courts must consider youth and attendant characteristics.
What must courts consider under Miller/Montgomery?	State: Miller requires general consideration of youth; no specific checklist.	Holman: Trial courts must consider Miller’s listed characteristics (immaturity, family environment, role in offense, competence, rehabilitation prospects).	Adopted list: courts must consider the Miller factors (age/immaturity, family/home, role/peer pressures, competence, prospects for rehabilitation), among others.
When reviewing pre‑Miller discretionary LWOP, what record matters?	State: Courts may consider post‑sentence conduct.	Holman: Only evidence of youth/characteristics at time of sentencing matters.	Only the “cold record” (evidence available at original sentencing) matters; post‑sentencing conduct cannot justify incorrigibility.
Did Holman’s original sentencing comply with Miller?	State: Trial court considered relevant evidence (PSI, reports, trial) and made a discretionary judgment.	Holman: Trial court failed to consider youth‑related mitigating evidence and declared no mitigating factors.	Held: The trial court sufficiently considered youth‑related evidence (record contained PSI and psychological reports; defendant declined to present mitigation), so Holman’s sentence survives Miller review.

Key Cases Cited

Miller v. Alabama, 567 U.S. 460 (2012) (mandatory LWOP for juveniles unconstitutional; sentencer must consider youth and attendant characteristics)
Montgomery v. Louisiana, 577 U.S. 190 (2016) (Miller applies retroactively; hearings must separate those juveniles for whom LWOP is proportionate)
Roper v. Simmons, 543 U.S. 551 (2005) (death penalty barred for juvenile offenders; juveniles are constitutionally different)
Graham v. Florida, 560 U.S. 48 (2010) (barred mandatory LWOP for juveniles in nonhomicide cases; emphasized youth’s diminished culpability)
People v. Davis, 2014 IL 115595 (Ill. 2014) (Miller’s rule is substantive and applies retroactively; discretionary LWOP not facially invalid absent Miller considerations)
People v. Thompson, 2015 IL 118151 (Ill. 2015) (distinguishes facial vs. as‑applied challenges; factual development needed for as‑applied claims)