People v. Jones
2020 IL App (3d) 140573
Ill. App. Ct.2020Background
- At 16, Robert Christopher Jones was indicted for multiple offenses including two murders; he pleaded guilty pursuant to a fully negotiated plea to one count of first‑degree murder, one count of residential burglary, and two counts of armed robbery.
- As part of the plea he waived a mitigation/aggravation hearing and the preparation of a presentence investigation report.
- The trial court sentenced him to concurrent terms: 50 years (murder), 15 years (burglary), and 30 years (each armed robbery).
- Jones later filed postconviction petitions; after an initial petition was denied, he sought leave to file a successive petition arguing his negotiated 50‑year term is a de facto life sentence under Miller and Buffer.
- The trial court denied leave to file the successive petition; the appellate court affirmed (after vacating an earlier panel decision under the Illinois Supreme Court’s supervisory order to consider People v. Buffer).
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Jones) | Held |
|---|---|---|---|
| Whether Jones may obtain leave to file a successive postconviction petition under the cause-and-prejudice test based on Miller and related decisions | Miller and related law do not entitle Jones to relief because his plea waived constitutional challenges to his sentence | Miller (and Buffer) render Jones’s 50‑year term a de facto life sentence and Miller’s protections require a new review of juvenile sentencing | Denied: Jones established cause (new law) but failed to show prejudice because his fully negotiated plea waived the claim |
| Whether a negotiated sentence can be attacked under Miller as a de facto life term | N/A (State relies on plea waiver doctrine) | The negotiated 50‑year term is effectively a life term for a juvenile and therefore unconstitutional under Miller/Buffer | Rejected: plea waiver bars Miller‑based challenge to a fully negotiated sentence |
| Whether facing a possible mandatory natural life sentence at trial made Jones’s plea involuntary or coerced | The plea was knowingly and voluntarily made; admonitions and plea colloquy support voluntariness | Plea was compelled by the prospect of a mandatory life sentence in the absence of Miller | Rejected: plea was voluntary; subsequent legal developments do not retroactively invalidate voluntariness (Brady) |
Key Cases Cited
- Miller v. Alabama, 567 U.S. 460 (U.S. 2012) (mandatory life without individualized youth consideration violates Eighth Amendment)
- Graham v. Florida, 560 U.S. 48 (U.S. 2010) (life without parole for nonhomicide juvenile offenders unconstitutional)
- Roper v. Simmons, 543 U.S. 551 (U.S. 2005) (juvenile death penalty unconstitutional)
- People v. Buffer, 2019 IL 122327 (Ill. 2019) (Illinois: sentences greater than 40 years are de facto life sentences)
- People v. Davis, 2014 IL 115595 (Ill. 2014) (Miller applies retroactively; explains cause-and-prejudice test for successive petitions)
- People v. Townsell, 209 Ill. 2d 543 (Ill. 2004) (fully negotiated guilty plea waives nonjurisdictional and constitutional claims)
- Brady v. United States, 397 U.S. 742 (U.S. 1970) (a plea remains voluntary despite later judicial changes in applicable maximum penalty)