People v. McKee
2017 IL App (3d) 140881
Ill. App. Ct.2017Background
- In January 2013, two men (Eric Glover and Terrance Rankins) were lured to a Joliet residence and later found strangled; defendants Miner and Landerman were the admitted killers. McKee was implicated as part of the group.
- McKee (age 18 at the time) helped plan the robbery, lured the victims to the house, left the room on a prearranged signal while the attack occurred, participated in taking property and proceeds, and joined post-offense discussions about disposing of the bodies.
- McKee was arrested, waived Miranda, and gave a recorded statement admitting involvement in planning, taking items, receiving money, and participating in post-offense acts.
- She was convicted by bench trial of two counts of first-degree murder on an accountability theory and, under 730 ILCS 5/5-8-1(a)(1)(c)(ii), received mandatory natural life imprisonment for multiple-victim murder.
- At sentencing McKee presented extensive traumatic history and mental-health evidence; defense argued mandatory life for an accomplice who was 18 violated the Eighth Amendment and Illinois proportionate-penalties clause.
- The trial court expressed sympathy but said it lacked discretion under the statute; it denied McKee’s motion to reconsider. McKee appealed, raising an as-applied constitutional challenge to her mandatory life term.
Issues
| Issue | Plaintiff's Argument (People) | Defendant's Argument (McKee) | Held |
|---|---|---|---|
| Whether mandatory natural life for multi-victim first-degree murder is unconstitutional as applied to McKee | Statute valid; applies to adult accomplices and trial record does not show disproportionality | Mandatory life for an 18‑year‑old accomplice with trauma/immaturity evidence is cruel and violates Illinois proportionate-penalties clause | Affirmed; statute constitutional as applied — McKee’s role and culpability distinguish her from juvenile cases |
| Whether Miller (juvenile precedent) extends to young adults to bar mandatory life | Miller limited to juveniles; adults treated differently | Scientific evidence of young-adult brain immaturity should allow Miller-like relief for young adults | Rejected: McKee is an adult, played an instigating role, and did not develop record on neurodevelopmental evidence, so Miller does not aid her |
| Whether appellate courts should follow First District decisions (House/Harris) that struck similar sentences for young adults | People argued earlier district decisions are not binding and are distinguishable | McKee urged following House/Harris to find sentence unconstitutional for young adult | Court declined to follow those First District decisions here due to factual differences and lack of supporting record/evidence |
| Whether the record supported extending juvenile-development science to McKee’s circumstances | Statutory scheme bars consideration; record lacks expert proof tying science to McKee | Defense urged consideration of trauma and youth-related brain development despite age 18 | Court found record insufficient: no expert or factual development showing how the science applied to McKee; statutory mandate controlled sentencing |
Key Cases Cited
- People v. Miller, 202 Ill. 2d 328 (Ill. 2002) (held mandatory natural life may be unconstitutional as applied to juveniles; requires case‑specific review)
- People v. Thompson, 2015 IL 118151 (Ill. 2015) (as-applied challenges demand a developed record showing how relied-on science/factors apply)
- Graham v. Florida, 560 U.S. 48 (2010) (Eighth Amendment prohibits punishments disproportionate to the crime)
- Kennedy v. Louisiana, 554 U.S. 407 (2008) (Eighth Amendment proportions and applicability to states via Fourteenth Amendment)