People v. Smith, 2015 IL 116572

Mickey D. Smith pleaded guilty to first‑degree murder (count II) as part of a plea deal: State dismissed other counts, recommended 30 years, and withdrew a notice seeking a 25‑year–to‑natural‑life firearm enhancement.
The factual basis accepted by the court established Smith entered a garage armed with a handgun and fired a single fatal shot.
The circuit court accepted the plea, admonished Smith based on the State’s withdrawal of the enhancement, and sentenced him to 30 years; no direct appeal was filed.
After People v. White (2011), Smith filed a pro se postconviction petition arguing his sentence and plea were void because the factual basis established a mandatory firearm enhancement that the court failed to impose.
The trial court summarily dismissed the petition; the appellate court reversed, holding White applied and the 30‑year sentence was void because the minimum with enhancement exceeded 30 years.
The Illinois Supreme Court granted review to decide whether White announced a new rule and thus whether it applies retroactively to convictions that were final when White was decided.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Smith)	Held
Whether White announced a new rule of law	White merely applied long‑standing void‑sentence principles; not new	White reaffirmed existing rule that unauthorized sentences are void so it applies	Court: White announced a new rule (it held for first time that a court cannot disregard facts in the accepted factual basis that trigger mandatory enhancements)
Whether White applies retroactively to convictions final before White	Teague bars retroactive application because White is a new rule and fits no exception	White should apply because it simply reaffirmed that statutorily unauthorized sentences are void	Court: Under Teague, White does not apply retroactively to final convictions (no Teague exception met)
Whether Smith’s sentence is void under postconviction Act	State: White is nonconstitutional and not retroactive; petition fails	Smith: Void‑sentence doctrine allows collateral challenge; White requires relief	Court: Smith not entitled to relief; postconviction petition properly dismissed because White is nonretroactive new rule
Whether the void‑sentence doctrine should be overruled (alternative State argument)	State (in reply): doctrinal basis for void rule is outdated and should be abandoned	Smith: relies on existing void‑sentence precedent	Court: Argument waived and unnecessary to decide; left intact for this case

People v. White, 2011 IL 109616 (held trial court must impose mandatory enhancement when factual basis accepted shows use of firearm)
Teague v. Lane, 489 U.S. 288 (1989) (retroactivity framework for new rules; two narrow exceptions)
Schriro v. Summerlin, 542 U.S. 348 (2004) (Teague framework applies to nonconstitutional rules)
People v. Thompson, 209 Ill. 2d 19 (2004) (void sentencing order may be challenged collateraly)
People v. Arna, 168 Ill. 2d 107 (trial court lacks authority to impose sentence outside statutory range)
People v. Hodges, 234 Ill. 2d 1 (2009) (overview of Post‑Conviction Hearing Act stages)