People v. Logan
2024 IL App (5th) 230019-U
Ill. App. Ct.2024Background
- Wade A. Logan was charged in 2003 with 11 counts related to the beating death of James Freeman and the aggravated battery of Freeman’s wife.
- Logan entered a fully negotiated guilty plea, receiving a 50-year sentence for first degree murder and a consecutive 3.5-year term for aggravated battery, with no direct appeal thereafter.
- In 2014, Logan filed a postconviction petition for resentencing under Miller v. Alabama, arguing that his youth was not properly considered at sentencing.
- The circuit court summarily dismissed the petition, but the appellate court initially reversed, finding he had alleged the gist of a Miller claim.
- On remand, after further proceedings, the Illinois Supreme Court decided People v. Jones, which held that Miller claims were barred for sentences resulting from fully negotiated guilty pleas.
- Based on Jones, the circuit court dismissed Logan's petition; his appellate counsel found no meritorious ground for appeal and sought to withdraw, which the court granted while affirming the judgment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Logan can raise a Miller claim after a fully negotiated plea | Miller applies to sentences of juveniles that are de facto life terms | Jones bars Miller claims for negotiated pleas | Jones bars Logan’s Miller claim given the guilty plea |
| Whether State was bound by concession for resentencing | Concession granted under old law | State withdrew after Jones | State could withdraw; Jones changed the law |
| Whether postconviction counsel complied with Rule 651(c) | N/A | Counsel met requirements | Rule 651(c) was satisfied; certificate was filed |
| Whether the postconviction petition alleged a substantial constitutional violation | Miller/Buffer support claim | Claim barred by waiver under plea agreement | No substantial claim under current binding precedent |
Key Cases Cited
- Miller v. Alabama, 567 U.S. 460 (U.S. 2012) (prohibits mandatory life without parole sentences for juveniles without consideration of youth-related factors)
- People v. Jones, 2021 IL 126432 (Ill. 2021) (bars Miller claims for sentences imposed pursuant to fully negotiated guilty pleas)
- People v. Buffer, 2019 IL 122327 (Ill. 2019) (defines de facto life sentences for juveniles as those longer than 40 years)