People v. Jackson, 2012 IL App (1st) 100398

Defendant Tarue Jackson, age 15, was charged with aggravated criminal sexual assault and aggravated criminal sexual abuse under a provision automatic transferring qualifying juveniles to adult court.
The automatic transfer provision, 705 ILCS 405/5-130, required his case to be prosecuted in criminal court given the charged offenses.
A jury convicted Jackson of two counts of aggravated criminal sexual assault and one count of aggravated criminal sexual abuse; two similar counts were acquitted.
Sentences were seven years for each aggravated sexual assault count and four years for the sexual abuse count, with a combined prison term constrained by statutory minimums/maxims.
Defendant challenged the automatic transfer provision as unconstitutional on due process, cruel and unusual punishment, and proportional penalties grounds; the trial court defenses on evidentiary rulings were also appealed.
The appellate court affirmed the convictions and upheld the automatic transfer provision as constitutional.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether automatic transfer violates due process	Jackson contends transfer is not supported by due process after Roper/Graham.	Jackson argues transfer lacks rational basis in light of Supreme Court rulings.	No due process violation; J.S. remains controlling; rational basis upheld.
Whether automatic transfer constitutes cruel and unusual punishment	Jackson argues transfer itself is punishment in violation of Eighth Amendment.	Argues transfer is not punishment; not subject to Eighth Amendment.	No Eighth Amendment violation; transfer is not a punishment.
Whether automatic transfer violates the proportional penalties clause	Jackson claims transfer exposure to harsher penalties violates the Illinois constitution.	Argues provision does not impose punishment; not within penalty clause.	Proportional penalties clause not violated; provision not a penalty.
Whether evidentiary rulings deprived defendant of a fair trial	Defense claims bias-motive exploration and expert access were improperly restricted.	Arguments about interview rights and expert table access challenged as necessary to defense.	No reversible error; trial court rulings within discretion; no denial of a fair trial.

People v. J.S., 103 Ill. 2d 395 (1984) (automatic transfer upheld under rational basis review)
People v. M.A., 124 Ill. 2d 135 (1988) (continued validity of automatic transfer for certain offenses)
People v. Miller, 202 Ill. 2d 328 (2002) (limited double-purpose look at disproportional sentencing context)
People v. Salas, 2011 IL App (1st) 091880 (2011) (addressed due process challenges to automatic transfer (appellate decision))
People v. P.H., 145 Ill. 2d 209 (1991) (procedural due process framework in juvenile cases)
People v. Becker, 239 Ill. 2d 215 (2010) (prohibition on comments about witness credibility by experts; limits on expert testimony)
People v. Cardamone, 381 Ill. App. 3d 462 (2008) (limits on expert admissibility and credibility commentary)
People v. Wheeler, 226 Ill. 2d 92 (2007) (standard for reviewing sufficiency and credibility in trials)
People v. Landis, 229 Ill. App. 3d 128 (1992) (separate evidentiary considerations in sexual offense cases)
In re Rodney H., 223 Ill. 2d 510 (2006) (proportional penalties analysis related to juvenile proceedings)
Kent v. United States, 383 U.S. 541 (1966) (due process scrutiny in juvenile transfer decisions (cited for context))