People v. Watson
201 N.E.3d 63
Ill. App. Ct.2021Background
- In December 2012, 17-year-old Britany Watson lured 38-year-old Sherman Horton to his car as part of a planned robbery at which she conspired with Lavell Blanchard.
- Watson texted Blanchard to "hit this lick," remained in the car during the setup, and asked him to hurry when Horton grew suspicious.
- Blanchard arrived armed, tapped Horton’s window, and shot Horton through the window; Horton later died. Watson ran, later claimed she had arranged the robbery but did not expect Horton to be shot.
- Watson was convicted of first-degree murder under Illinois' felony-murder and common-design accountability doctrines and sentenced to 25 years (court declined a 15-year firearm enhancement).
- On appeal Watson argued (1) due process forbids convicting juveniles of murder under felony-murder/accountability when they neither killed nor intended to kill (relying on Roper/Graham/Miller), and (2) her 25-year sentence was excessive.
- The appellate court affirmed: it rejected Watson's due-process and facial challenges and upheld the sentence as within statutory range and not an abuse of discretion.
Issues
| Issue | Plaintiff's Argument (People) | Defendant's Argument (Watson) | Held |
|---|---|---|---|
| Whether due process bars convicting a juvenile of 1st-degree murder under felony-murder or common-design accountability when the juvenile neither killed nor intended to kill | Statutes are constitutional; states may define criminal liability; felony-murder and accountability do not require intent to kill or foreseeability | Juveniles’ diminished maturity/foresight (per Roper/Graham/Miller) means due process forbids convicting a juvenile for murder they did not commit or intend | Rejected. No fundamental due-process right exempts such juveniles; felony-murder and accountability historically permissible and constitutionally permissible here |
| Whether statutes fail rational-basis review as applied to juveniles | Felony-murder and accountability rationally further deterrence and public safety; statutes attach liability for underlying felony regardless of intent to kill | No rational basis to treat juveniles as equally culpable given lack of foreseeability and immature judgment | Rejected. Rational basis satisfied; statutes do not require foreseeability or intent to kill; proximate-cause/foreseeability only applies where a third party (not a co-felon) causes death |
| Whether Watson's 25-year sentence is excessive given she neither shot nor intended to kill | Sentence within statutory range (20–60); court showed leniency by declining firearm enhancement; sentencing discretion appropriate | 25 years is disproportionate for a juvenile non-shooter with no intent to kill | Rejected. Sentence is within statutory limits, near the minimum, and not an abuse of discretion |
Key Cases Cited
- Miller v. Alabama, 567 U.S. 460 (2012) (mandatory life-without-parole for juveniles convicted of homicide is unconstitutional)
- Graham v. Florida, 560 U.S. 48 (2010) (life-without-parole for juveniles in nonhomicide cases is unconstitutional)
- Roper v. Simmons, 543 U.S. 551 (2005) (death penalty for juvenile offenders unconstitutional)
- Kahler v. Kansas, 140 S. Ct. 1021 (2020) (due process does not mandate a specific historical insanity test; courts should look to history and tradition)
- People v. Dennis, 181 Ill. 2d 87 (1998) (purpose of felony-murder is to deter forcible felonies and impose broad liability)
- People v. Klebanowski, 221 Ill. 2d 538 (2006) (felony-murder conviction may be sustained absent intent to commit murder)
- People v. Lowery, 178 Ill. 2d 462 (1997) (Illinois follows proximate-cause theory when a third party resisting the felony causes death)
- People v. Hudson, 222 Ill. 2d 392 (2006) (foreseeability instruction required when co-felon is killed by an off-duty officer; proximate-cause analysis)
- State v. Harrison, 914 N.W.2d 178 (Iowa 2018) (rejecting due-process challenge to juvenile felony-murder liability under aiding-and-abetting theory)