People v. Stafford, 2016 IL App (4th) 140309

In March 2002, 17‑year‑old David P. Stafford stabbed Cherie Gillson to death during a residential burglary; the victim suffered at least 45 stab wounds. Stafford confessed and was linked to stolen videotapes found in his room.
A jury convicted Stafford of four counts of first‑degree murder and one count of first‑degree felony murder; the trial court sentenced him to natural life in prison (no parole).
Stafford filed a pro se postconviction petition (June 2013) arguing his life sentence violated the Eighth Amendment under Miller v. Alabama because he was a juvenile (17) at the time of the offense.
The State moved to dismiss, arguing Miller invalidated only mandatory life‑without‑parole schemes and Stafford received a discretionary life sentence; the trial court granted the motion and dismissed the petition at the second stage.
On appeal Stafford argued (1) his sentence was void because the felony‑murder statute allegedly required the offender be 18 for the enhancement, and (2) under Miller (and Montgomery) his discretionary life sentence was unconstitutional without individualized youth‑based consideration. The appellate court affirmed dismissal.

Issue	Plaintiff's Argument (People)	Defendant's Argument (Stafford)	Held
1. Whether Stafford’s sentence is void/unauthorized by statute	Castleberry abolishes the void‑sentence rule prospectively; sentence not void	Stafford says felony‑murder enhancement required age 18 so sentence is void and challengeable anytime	Court: Castleberry applies; only jurisdictional defects render a sentence void. Stafford did not challenge jurisdiction; no relief.
2. Whether Miller/Montgomery require resentencing for a juvenile given a discretionary natural life term	State: Miller targeted mandatory LWOP; discretionary life does not automatically trigger relief; sentencing record considered youth	Stafford: Miller and Montgomery mandate individualized consideration of youth even for discretionary life sentences; he is entitled to resentencing	Court: Miller/Montgomery apply, but record shows the trial court considered youth and related factors and concluded Stafford was among the rare juveniles warranting life; no improper factors relied upon — no resentencing needed.

Miller v. Alabama, 567 U.S. 460 (2012) (mandatory juvenile life‑without‑parole unconstitutional; courts must consider youth and its hallmarks)
Montgomery v. Louisiana, 577 U.S. 190 (2016) (Miller applies retroactively in collateral review; reserved life sentences for rare irreparably corrupt juveniles)
Roper v. Simmons, 543 U.S. 551 (2005) (death penalty unconstitutional for crimes committed under 18)
Graham v. Florida, 560 U.S. 48 (2010) (life‑without‑parole for nonhomicide juvenile offender unconstitutional)
Teague v. Lane, 489 U.S. 288 (1989) (new rules of criminal procedure generally do not apply retroactively to cases on collateral review)
People v. Castleberry, 2015 IL 116916 (Ill.) (abolished the broad void‑sentence rule; post‑Arna framework reinstated regarding when sentences are truly void)
People v. Arna, 168 Ill. 2d 107 (1995) (predecessor articulation of the void‑sentence rule)
People v. Davis, 156 Ill. 2d 149 (1993) (sentence void only when court lacked personal or subject‑matter jurisdiction)
McKinley v. Butler, 809 F.3d 908 (7th Cir. 2015) (interpreting Miller to require sentencing courts to account for how juveniles differ from adults)