People v. House
2021 IL 125124
| Ill. | 2021Background:
- In 1993 House (19 at the time) participated in kidnappings and shootings of two victims; convicted of two counts of first-degree murder and aggravated kidnapping.
- He was sentenced to mandatory natural life imprisonment for murders and consecutive terms for kidnappings.
- House filed a postconviction petition alleging (among other claims) that the mandatory natural-life statute violated the Illinois proportionate-penalties clause as applied to him (arguing young-adult brain science makes him analogous to juveniles) and an actual-innocence claim supported by a witness recantation.
- The appellate court vacated the life sentence as unconstitutional as applied and remanded for resentencing; this court issued a supervisory order directing reconsideration in light of People v. Harris.
- The Illinois Supreme Court held the appellate court erred in deciding the as-applied proportionate-penalties claim without a developed evidentiary record and remanded for second-stage postconviction proceedings; it also vacated the appellate court’s affirmance of the second-stage dismissal of the actual-innocence claim and remanded that claim for reconsideration in light of Sanders and Robinson.
Issues:
| Issue | Plaintiff's Argument (State) | Defendant's Argument (House) | Held |
|---|---|---|---|
| Whether House’s mandatory natural-life sentence violates the Illinois proportionate-penalties clause as applied | Appellate court erred: an as-applied challenge requires a developed record and factual findings (per Harris); claim was not developed below | The mandatory statute precludes individualized mitigation; young-adult brain science makes 18–21 analogous to juveniles so mandatory life is disproportionate | Reversed appellate court’s as-applied ruling; remanded to circuit court for second-stage postconviction proceedings so record can be developed |
| Whether House’s actual-innocence claim (witness recantation) was properly dismissed at second stage | State concedes reconsideration is warranted in light of later decisions (Sanders, Robinson) and asks remand to avoid piecemeal litigation | House urges immediate advancement to third-stage evidentiary hearing | Vacated appellate court’s affirmance of second-stage dismissal and remanded to trial court to reconsider the actual-innocence claim at second stage in light of Sanders and Robinson (no merits decision) |
Key Cases Cited
- People v. Harris, 2018 IL 121932 (as-applied constitutional claims require a developed evidentiary record; appellate courts should not decide as-applied claims in a factual vacuum)
- Miller v. Alabama, 567 U.S. 460 (2012) (mandatory life-without-parole for juveniles requires consideration of youth and attendant characteristics)
- Roper v. Simmons, 543 U.S. 551 (2005) (Supreme Court set age-18 categorical line for certain juvenile death-penalty protections; line-drawing is partly social-policy driven)
- People v. Robinson, 2020 IL 123849 (clarified actual-innocence standards for successive postconviction petitions and review at leave-to-file stage)
- People v. Sanders, 2016 IL 118123 (addressed standards for reviewing recantation-based actual-innocence claims at second stage)
- People v. Thompson, 2015 IL 118151 (discussed necessity of adequate record for as-applied constitutional challenges)
- People v. Coty, 2020 IL 123972 (statutes presumed constitutional; challenger must clearly establish invalidity when applied)