People v. Ramsey
2019 IL App (3d) 160759
Ill. App. Ct.2019Background
- Daniel Ramsey, 18 at the time of the offenses, pled guilty to two murders, multiple attempted murders, aggravated criminal sexual assault, and home invasion; originally sentenced to death and later resentenced to death after remand and a guilty plea.
- Ramsey filed a pro se postconviction petition in 2011; while it was pending, Illinois abolished the death penalty and Governor Pat Quinn commuted Ramsey’s death sentence to life without parole.
- Ramsey amended his postconviction petition arguing the commuted sentence violated the Eighth Amendment and the Illinois proportionate-penalties clause because it failed to consider his youth and other mitigating factors (citing Miller v. Alabama).
- At the second stage of postconviction proceedings the State moved to dismiss; the circuit court granted dismissal, holding among other things that executive commutations are not judicially reviewable.
- Ramsey appealed, arguing the commutation was unconstitutional because it did not account for his age/mitigating circumstances; the appellate court affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether an executively imposed commutation is immune from judicial review when it allegedly violates constitutional rights | Ramsey: The commuted life-without-parole sentence violated his constitutional rights (Eighth and Illinois proportionate-penalties clause) because it failed to consider his youth/mitigating factors; thus courts must review the commutation | State/Quinn: Clemency is an executive power not subject to judicial control; commutations are not reviewable by courts | Court: Clemency is not absolutely immune from review — executive commutations are constrained by constitutional protections and may be judicially considered when a constitutional right is implicated |
| Whether Ramsey’s commuted life-without-parole sentence violated the Eighth Amendment or Illinois proportionality clause (Miller claim) | Ramsey: Miller requires consideration of youth; his sentence is unconstitutional because it did not account for his age and mitigating factors | State: Miller applies to juvenile offenders under 18; Ramsey was 18 at offense; his violent solo conduct distinguishes him from cases affording leniency | Court: Eighth Amendment claim fails — Miller applies only to those under 18; proportionality claim fails — sentence does not shock the moral sense given Ramsey’s conduct; dismissal affirmed |
Key Cases Cited
- People v. Ramsey, 239 Ill. 2d 342 (Ill. 2010) (prior appeal discussing convictions and sentences)
- People ex rel. Madigan v. Snyder, 208 Ill. 2d 457 (Ill. 2004) (Governor’s clemency power is broad and not subject to control by courts or legislature)
- People v. Mata, 217 Ill. 2d 535 (Ill. 2005) (executive clemency does not automatically bar judicial review where a constitutional right—such as due process—is implicated)
- Miller v. Alabama, 567 U.S. 460 (U.S. 2012) (mandatory life-without-parole for juveniles violates the Eighth Amendment)
- People v. Miller, 202 Ill. 2d 328 (Ill. 2002) (framework for Illinois proportionality review)
- People v. Harris, 2018 IL 121932 (Ill. 2018) (confirmation that the legal line for juvenile/adult status remains at age 18)
- Hand v. Scott, 285 F. Supp. 3d 1289 (N.D. Fla. 2018) (federal discussion that executive clemency is not immune from constitutional constraints)