People v. Jackson
2016 IL App (1st) 143025
| Ill. App. Ct. | 2016Background
- In 2003 defendant Darron Jackson (age 16 at the offense) was tried as an adult, convicted of first-degree murder and personally discharging a firearm causing death, and originally sentenced to 60 years (reduced on direct appeal to 50 years).
- The firearm enhancement then was mandatory, producing a sentencing range of 45 years to natural life; truth-in-sentencing required serving the full term.
- Defendant filed a postconviction petition in 2008 (dismissed as frivolous); in 2014 he sought leave to file a successive postconviction petition claiming (1) his 50-year sentence is a de facto life term violative of the Eighth Amendment post-Miller and (2) Illinois’s automatic transfer statute is unconstitutional.
- The trial court denied leave to file the successive petition; the appellate court reviews that denial de novo on the pleadings and supporting documentation.
- The Illinois Legislature amended juvenile-sentencing law effective Jan. 1, 2016: raised the automatic-transfer age, made firearm enhancements discretionary for juveniles, and removed some mandatory juvenile life terms (prospective application declared).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether defendant showed prejudice under the cause-and-prejudice test to warrant filing a successive postconviction petition attacking his 50-year sentence under Miller | State: even if cause exists, no prejudice because Miller does not apply to fixed-term sentences like Jackson’s and Davis allows discretionary life terms | Jackson: 50 years is a de facto life-without-parole (exceeds life expectancy / no parole) and therefore runs afoul of Miller’s Eighth Amendment principles | Denied. Court held no prejudice shown; under Davis and existing precedent Miller does not require relief for Jackson’s discretionary-sentencing context, and resolving de facto life questions broadly is for higher authority or legislative policy changes |
| Whether the automatic-transfer provision (Juvenile Court Act) is unconstitutional under due process, the Illinois proportionate-penalties clause, or the Eighth Amendment | State: Patterson controls and upholds the automatic-transfer statute against these challenges | Jackson: automatic transfer (as applied with firearm enhancement and truth-in-sentencing) is unconstitutional for juveniles post-Miller | Denied. Court declined to overturn Patterson and held Jackson’s challenge fails as a matter of law |
Key Cases Cited
- Miller v. Alabama, 132 S. Ct. 2455 (2012) (holding mandatory life without parole for juveniles violates the Eighth Amendment and requires individualized sentencing consideration)
- Montgomery v. Louisiana, 136 S. Ct. 718 (2016) (holding Miller’s rule is retroactive and requires opportunity for juveniles sentenced to mandatory LWOP to show lack of irreparable corruption)
- People v. Davis, 2014 IL 115595 (Ill. 2014) (Illinois Supreme Court: Miller permits discretionary life sentences for juveniles and Miller’s rule constitutes "cause" for successive petitions)
- People v. Patterson, 2014 IL 115102 (Ill. 2014) (Illinois Supreme Court: upheld automatic-transfer statute against due process, Eighth Amendment, and Illinois proportionate-penalties challenges)
- People v. Smith, 2014 IL 115946 (Ill. 2014) (explaining standards for leave to file successive postconviction petitions and the pleading/documentation required)