People v. House
2019 IL App (1st) 110580-B
Ill. App. Ct.2019Background
- In 1993 Antonio House (age 19) was convicted—under an accountability theory—of two counts of first‑degree murder and two counts of aggravated kidnapping based on eyewitness testimony and his own handwritten statement; he acted as a lookout and drove persons to a meeting near railroad tracks where victims were shot.
- At trial House received two consecutive mandatory natural‑life sentences (for multiple murders) plus consecutive terms for kidnapping; post‑direct‑appeal proceedings vacated some sentences and affirmed convictions.
- House filed a postconviction petition (amended, raised multiple claims including as‑applied challenge to mandatory natural life under the Illinois proportionate penalties clause); most claims were previously adjudicated—only the proportionate‑penalties claim remained for reconsideration after the Illinois Supreme Court issued a supervisory order directing this court to reconsider in light of People v. Harris.
- The court compared House’s role (lookout, not shooter), his youth (19 years), lack of violent priors, and sentencing outcomes for codefendants (one lookout, 17 at offense, was resentenced and released) when assessing proportionality.
- The appellate court concluded House’s mandatory natural‑life sentence, imposed without consideration of youth and mitigating factors, is unconstitutional as applied and vacated that sentence, remanding for a new sentencing hearing where the court may consider mitigating evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether mandatory natural‑life for multi‑murderers violates Illinois’ proportionate penalties clause as‑applied to House | State: statute constitutional; case is distinguishable from juvenile cases and House’s claim is premature or forfeited | House: at 19, minimal role (lookout), no violent priors, youth and attendant characteristics make mandatory life disproportionate as‑applied | Vacated House’s mandatory life sentence as‑applied; remanded for new sentencing hearing to consider mitigating evidence |
| Whether House’s claim is premature because sentencing facts require trial‑court development (per People v. Harris) | State: claim premature; evidentiary development needed | House: claim preserved—raised at sentencing, on direct appeal, and in postconviction petition | Not premature here: House consistently raised claim and record plus analogies (Leon Miller, Buffer) warrant immediate resentencing hearing |
| Appropriate remedy and forum for further proceedings (second‑stage postconviction remand v. new sentencing hearing) | Parties (later): asked remand for second‑stage postconviction proceedings | House: sought relief via postconviction; court may order resentencing | Court denied duplicative second‑stage remand and ordered new sentencing hearing instead (remedy similar to Buffer) |
| Relevance of juvenile/young‑adult precedent (Roper/Graham/Miller/Buffer) to 19‑year‑old defendant convicted under accountability | State: adult at 19; Supreme Court juvenile decisions have limits; not a bright‑line rule forcing relief | House: young adult brain development and accountability conviction make life without parole disproportionate | Court applied juvenile‑development reasoning analogously to a 19‑year‑old lookout and relied on Miller/Leon Miller/Buffer principles to require resentencing |
Key Cases Cited
- Miller v. Alabama, 567 U.S. 460 (sentencing court must consider youth and attendant characteristics before life without parole for juveniles)
- Roper v. Simmons, 543 U.S. 551 (death penalty unconstitutional for juveniles; differences in maturity and culpability relevant)
- Graham v. Florida, 560 U.S. 48 (life without parole for nonhomicide juvenile offenders unconstitutional; youth relevant to proportionality)
- People v. Harris, 2018 IL 121932 (as‑applied proportionality claims may be premature on direct appeal where trial court has not fact‑found; evidentiary development often necessary)
- People v. Buffer, 2019 IL 122327 (a 40+ year term can be a de facto life sentence for Miller claims; remand for resentencing is appropriate when record suffices)
- People v. Miller (Leon Miller), 202 Ill. 2d 328 (Illinois Supreme Court held mandatory natural life as applied to a juvenile accountable lookout was unconstitutionally disproportionate)