People v. Pittman
2018 IL App (1st) 152030
Ill. App. Ct.2018Background
- In Nov. 2010, Denzel Pittman (age 18 at the time) was tried by bench trial and convicted of first-degree murder for stabbing to death Jade Hannah (17), her mother Stacy Cochran (43), and sister Joi Cochran (11).
- Forensic evidence: blood/DNA from the victims found on Pittman’s clothing; medical examiner testified multiple fatal stab wounds to each victim; jailhouse informant related an incriminating confession.
- Pittman was evaluated fit for sentencing; defense submitted mitigation materials (mental-health history, childhood exposure to violence, prior shooting injury) but presented no live mitigating testimony at sentencing.
- Under 730 ILCS 5/5-8-1(a)(1)(c)(ii) (multiple murders and murder of a child under 12), the trial court had no statutory discretion and imposed mandatory natural life sentences to run concurrently.
- On appeal Pittman did not challenge guilt; he argued the mandatory natural-life sentence (applied without consideration of his youth/other mitigating factors) violated the Eighth Amendment and Illinois proportionate-penalties clause.
- The appellate court affirmed, holding Miller-era Eighth Amendment protections apply to juveniles (under 18) and do not extend to adult offenders like Pittman; it also held the mandatory life sentence did not shock the moral sense of the community under Illinois proportionality review given the facts.
Issues
| Issue | State's Argument | Pittman’s Argument | Held |
|---|---|---|---|
| Whether mandatory natural life violated the Eighth Amendment as applied | Miller protections apply only to juvenile offenders; Pittman (18) is an adult so Eighth Amendment claim fails | Mandatory life without consideration of youth/mitigation is cruel and unusual; Miller/Montgomery principles should apply to "youthful" adults | Rejected — Miller/Montgomery apply to juveniles; no authority extends them to adult offenders; no plain error shown |
| Whether Illinois proportionate-penalties clause barred mandatory natural life | Given the brutal facts and multiple victims (including a child under 12), mandatory life is proportionate and within legislature’s authority | Mandatory life without individualized consideration shocks the moral sense of the community given Pittman’s age, mental health, background | Rejected — court found facts (perpetrator of multiple brutal murders including 11-year-old) make mandatory life proportionate; House decision inapplicable |
| Whether sentencing error was forfeited and reviewable | Pittman failed to object or file postsentencing motion; review only for plain error | Contended constitutional error warrants review despite forfeiture | Court applied plain-error standard and found no clear or obvious error |
| Whether trial court would have imposed same sentence if given discretion | N/A (State noted statute mandated life) | Requested individualized consideration might have produced lesser sentence | Trial court comments indicated it would have imposed natural life regardless, supporting affirmance |
Key Cases Cited
- Roper v. Simmons, 543 U.S. 551 (prohibits death penalty for juvenile offenders)
- Graham v. Florida, 560 U.S. 48 (bars life without parole for juveniles in nonhomicide cases; requires consideration of youth)
- Miller v. Alabama, 567 U.S. 460 (requires individualized sentencing consideration before life without parole for juvenile homicide offenders)
- Montgomery v. Louisiana, 136 S. Ct. 718 (made Miller’s rule retroactive; sentencing must account for youth and attendant characteristics)
- People v. Miller, 202 Ill. 2d 328 (explains legislature’s authority and proportionality framework under Illinois Constitution)