People v. Jones
2016 IL 119391
| Ill. | 2017Background
- Derrick Jones was convicted of aggravated robbery (Class 1) and sentenced to an extended-term (24 years) based on a presentence report indicating a 2005 juvenile adjudication for multiple offenses including three counts of residential burglary.
- At trial no evidence of the juvenile adjudication was presented to the jury; the PSI documented the juvenile dispositions and listed "Juvenile Probation" for the burglary counts.
- Jones raised a sentencing challenge on direct appeal: he argued using the juvenile adjudication to impose an extended term violated Apprendi (and Illinois §111-3(c-5)) because it was not alleged in the indictment nor proven to a jury beyond a reasonable doubt; alternatively he argued the PSI was an unreliable source under Shepard.
- The Illinois Appellate Court affirmed; the Illinois Supreme Court granted leave to appeal and again affirmed the appellate court.
- The majority held (1) a prior juvenile adjudication counts as a “prior conviction” for Apprendi’s prior-conviction exception and Illinois §111-3(c-5), and (2) the PSI here conclusively established the juvenile adjudication and did not violate Shepard.
- A dissent argued that Illinois precedent treats "conviction" as excluding juvenile adjudications for statutory purposes, so the legislature’s wording in §111-3(c-5) requires pleading/proof beyond a reasonable doubt before using the adjudication to enhance a sentence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a prior juvenile delinquency adjudication is a “prior conviction” under Apprendi and §111-3(c-5) so it may be used to enhance sentence without being alleged/proved to a jury | State: juvenile adjudications are functionally equivalent to prior convictions for sentencing because juvenile proceedings afford constitutionally sufficient safeguards | Jones: juvenile adjudications are not "convictions" for statutory purposes; Apprendi/§111-3(c-5) require pleading/proof beyond a reasonable doubt | Majority: juvenile adjudications fall within Apprendi’s prior-conviction exception and §111-3(c-5) need not be triggered; no Apprendi error |
| Whether the PSI provided an adequate, permissible basis to establish the juvenile adjudication (Shepard issue) | State: a statutorily compiled PSI is a reliable criminal-history source and here unequivocally shows adjudication for residential burglary | Jones: PSI is ambiguous/tenuous and akin to documents disallowed by Shepard; cannot be sole basis for enhancement | Court: PSI here was statutorily sufficient, unambiguous, and unlike the police reports Shepard rejected; reliance did not violate Shepard |
Key Cases Cited
- Apprendi v. New Jersey, 530 U.S. 466 (U.S. 2000) (facts increasing statutory maximum must be submitted to a jury, except prior convictions)
- Shepard v. United States, 544 U.S. 13 (U.S. 2005) (limits sentencing-court reliance to certain documents when determining prior convictions under ACCA)
- Almendarez-Torres v. United States, 523 U.S. 224 (U.S. 1998) (recognized prior-conviction exception to element/pleading requirement)
- Jones v. United States, 526 U.S. 227 (U.S. 1999) (distinguished factors that increase penalties and held some penalty provisions define separate elements)
- McKeiver v. Pennsylvania, 403 U.S. 528 (U.S. 1971) (no constitutional right to jury trial in juvenile adjudicatory proceedings)
- People v. Taylor, 221 Ill. 2d 157 (Ill. 2006) (distinguished issue of juvenile adjudication as a statutory "conviction" from the Apprendi sentencing question)
