People v. Suggs
2020 IL App (2d) 170632
Ill. App. Ct.2020Background
- In May 2007 Montago E. Suggs (age 23 at the time) robbed a Check ’n Go in Waukegan and, during the incident, Melinda Morrell was shot in the back of the head and killed; five days later he attempted a similar armed robbery at a convenience store and fled after the gun did not fire.
- Suggs was convicted of first-degree murder (Morrell) and of attempted murder and attempted armed robbery (bench stipulation) and received an aggregate sentence of 110 years (80 years for murder — 55 + 25 firearm add-on — consecutive to concurrent 30- and 28-year terms).
- At sentencing the court considered PSI, victim impact statements, defendant’s juvenile/adult criminal history, disciplinary infractions in custody, and found the crimes were planned and particularly aggravating; the court expressed intent for Suggs to spend the rest of his life in prison.
- Suggs filed a pro se postconviction petition contending his aggregate sentence is a de facto life sentence that violates the Eighth Amendment because the court failed to account for his youth/immaturity, and that the sentence violated Illinois’s rehabilitation clause by not giving sufficient weight to amenability to rehabilitation.
- The trial court summarily dismissed the petition as without merit and as issues that could have been raised on direct appeal; Suggs appealed the dismissal.
- The appellate court affirmed, holding juvenile sentencing precedents (Roper/Graham/Miller/Montgomery and Illinois cases applying them) do not extend to a 23‑year‑old here, and the record supports the court’s finding that Suggs did not exhibit the signature qualities of youth and that the court did not abuse its sentencing discretion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Suggs’s aggregate 110‑year sentence is an Eighth Amendment violation as a de facto life sentence warranting juvenile‑style protections | The State: sentence was within statutory limits and not cruel or manifestly disproportionate | Suggs: at 23 he still lacked full maturity; emerging science shows brain maturation into mid‑20s so juvenile protections should extend to him and require consideration of youth/rehabilitation | Denied — court declines to extend Roper/Graham/Miller/Montgomery protections to a 23‑year‑old; record shows planning and sophistication inconsistent with juvenile signature qualities, so as‑applied challenge fails |
| Whether the sentence violated the Illinois Constitution’s rehabilitation clause by failing to account for transient youth and amenability to rehabilitation | The State: trial court considered mitigation and aggravation and did not abuse discretion | Suggs: court gave insufficient weight to youth and rehabilitation prospects | Denied — sentencing within statutory limits and not an abuse of discretion; court reasonably found limited rehabilitative potential based on record (behavior, prior failures of probation) |
| Procedural/forfeiture issues in postconviction context (can these claims be raised here) | The State: issues that were or could have been raised on direct appeal are forfeited/res judicata in postconviction proceedings | Suggs: raised constitutional sentencing arguments in postconviction petition | Held: Court enforces forfeiture/res judicata where appropriate but also addresses merits; nisi — defendant’s rehabilitation‑clause complaint was forfeited for failure to raise on direct appeal, and sentencing claim otherwise lacks merit |
Key Cases Cited
- Miller v. Alabama, 567 U.S. 460 (prohibits mandatory life without parole for juvenile homicide offenders)
- Roper v. Simmons, 543 U.S. 551 (bars death penalty for juvenile offenders)
- Graham v. Florida, 560 U.S. 48 (bars mandatory life without parole for juveniles convicted of nonhomicide offenses)
- Montgomery v. Louisiana, 136 S. Ct. 718 (Miller retroactivity and requirement that courts consider youth before life terms)
- People v. Buffer, 2019 IL 122327 (Illinois supreme court on de facto life sentences and youth consideration)
- People v. Holman, 2017 IL 120655 (Illinois supreme court: juvenile life sentences—mandatory or discretionary—require youth consideration)
- People v. Reyes, 2016 IL 119271 (Illinois supreme court extending Miller rationale to de facto life sentences)
- People v. Veach, 2017 IL 120649 (procedural rules on raising sentencing errors on direct appeal)
- People v. Stacey, 193 Ill. 2d 203 (review standard for sentences within statutory limits)