People v. Hoover, 2019 IL App (2d) 170070

Michael D. Hoover (age 22 at offense) was convicted at jury trial of first‑degree murder (as an accomplice) and armed robbery for a November 1992 gun‑shop killing; he had confessed and initially pleaded guilty but withdrew that plea.
The victim suffered multiple gunshot wounds and a fatal throat cutting; the trial court found the murder accompanied by exceptionally brutal or heinous conduct and sentenced Hoover to an extended term of life imprisonment for murder and an extended 50 years (later reduced) for armed robbery.
Hoover had an extensive adult criminal history (multiple convictions and prior prison terms); the sentencing court found his rehabilitative potential to be "almost nil."
Hoover’s direct appeal affirmed the murder sentence; later postconviction petitions (including an Apprendi claim) were dismissed.
In 2016 Hoover sought leave to file a successive postconviction petition arguing (based on Miller v. Alabama and related authority) that his life sentence violated the Eighth Amendment and Illinois’s proportionate‑penalties clause; the trial court denied leave and the denial is appealed.
The appellate court, applying People v. LaPointe and People v. Harris, held Hoover failed to demonstrate cause and prejudice under 725 ILCS 5/122‑1(f) for his proportionate‑penalties challenge and affirmed the denial of leave.

Issue	Plaintiff's Argument (People)	Defendant's Argument (Hoover)	Held
Whether Hoover’s Eighth Amendment/Miller‑based claim (applying Miller to a 22‑year‑old) satisfied section 122‑1(f) for a successive petition	Miller applies only to offenders under 18; claim fails as a matter of law	Miller’s findings about youth/brain science support applying the Miller "principle" to "young adults," so leave should be granted	Denied; Hoover abandoned the Eighth Amendment claim after People v. Harris showed Miller does not apply to ages 18 and older
Whether Hoover’s proportionate‑penalties clause claim satisfied section 122‑1(f) (cause and prejudice)	The claim could have been raised earlier; Miller did not create a new, constitutionally‑required sentencing right for adults; the petition does not show constitutional prejudice and is barred by forfeiture/res judicata and lacking in merit	Miller (and later cases) provide new support showing youth is mitigating and trial court ignored youth and rehabilitative potential, so cause exists and prejudice would follow	Denied; court held Hoover could have raised the claim earlier (no cause), the alleged error was sentencing‑discretion not a constitutional deprivation, the claim was forfeited/res judicata, and on the merits the life sentence was not grossly disproportionate nor shocking to the community

Miller v. Alabama, 567 U.S. 460 (2012) (mandatory life without parole for offenders under 18 violates Eighth Amendment)
Apprendi v. New Jersey, 530 U.S. 466 (2000) (rule cited in prior collateral challenge; noted not retroactive to Hoover’s earlier postconviction proceeding)
People v. LaPointe, 88 Ill. 2d 482 (Ill. 1981) (trial court not required to make detailed record findings about rehabilitative potential; life sentence upheld)
People v. Harris, 2018 IL 121932 (Ill. 2018) (Miller does not apply to defendants 18 years or older)
People v. Sharpe, 216 Ill. 2d 481 (Ill. 2005) (standard for disproportionality: sentence must "shock the moral sense of the community")
People v. Moss, 206 Ill. 2d 503 (Ill. 2003) (disproportionality standard and analysis under proportionate‑penalties clause)
People v. Patterson, 2014 IL 115102 (Ill. 2014) (discussion of relationship between Eighth Amendment and Illinois proportionate‑penalties clause)
People v. Clemons, 2012 IL 107821 (Ill. 2012) (proportionate‑penalties clause may provide broader protection than Eighth Amendment)