People v. Williams
2012 IL App (1st) 111145
Ill. App. Ct.2012Background
- People v. Williams involves postconviction petitions (third and fourth) challenging a juvenile mass-murder sentence; the circuit court dismissed the third petition and denied leave for a fourth petition, and this court consolidates appeals.
- The third petition alleges actual innocence based on newly discovered affidavits from codefendants and a girlfriend, plus Brady and probable-cause challenges.
- The fourth petition argues Miller v. Alabama renders mandatory life without parole for a juvenile unconstitutional and seeks a remand for resentencing.
- The court previously held some affidavits were newly discovered, material, and noncumulative, entitling a potential evidentiary hearing on the third petition, which this panel reversed on remand.
- The central thrust is whether Miller applies retroactively to permit relief on the fourth petition and whether a new sentencing hearing is required if Miller applies.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Retroactivity of Miller v. Alabama | Williams argues Miller applies retroactively. | State contends Miller is procedural and not retroactive. | Miller retroactive under Teague framework; requires relief. |
| Entitlement to evidentiary hearing on actual innocence | Newly discovered affidavits show actual innocence; material and noncumulative. | Affidavits were not new, noncumulative, or likely to change result. | Defendant entitled to an evidentiary hearing on the third petition. |
| Cause-and-prejudice standard for fourth petition | Miller created new rule requiring retroactive relief; cause satisfied. | Need to show cause and prejudice under 122-1(f). | Cause satisfied; Miller applied retroactively; fourth petition viable. |
| Whether sentence violated Eighth Amendment under Miller | Mandatory life without parole for a juvenile violates Miller’s reasoning. | Sentence procedure complied with law; Miller does not apply to final convictions. | Sentence unconstitutional under Miller; resentencing required if remanded. |
| Impact of Miller on resentence procedures | Remand for new sentencing hearing appropriate. | Procedural safeguards already followed. | Remand for resentencing if needed; Miller requires proper individualized consideration. |
Key Cases Cited
- Miller v. Alabama, 132 S. Ct. 2455 (2012) (mandatory LWOP for juveniles violates Eighth Amendment; retroactivity discussed under Teague)
- Teague v. Lane, 489 U.S. 288 (1989) (new rules generally not retroactive on collateral review; watershed-rule exception)
- Graham v. Florida, — (2010) (juveniles’ sentencing considerations; used in Miller context (official reporter not provided in text))
- People v. Flowers, 138 Ill. 2d 218 (1990) (Teague framework adopted by Illinois Supreme Court for retroactivity)
- People v. Ortiz, 235 Ill. 2d 319 (2009) (cause-and-prejudice test for successive postconviction petitions)
- People v. Morgan, 212 Ill. 2d 148 (2004) (newly discovered evidence and innocence claims; standard for hearing)
- People v. Peeples, 205 Ill. 2d 480 (2002) (standard for entertaining postconviction petitions; de novo review on dismissal)
- People v. Purnell, 356 Ill. App. 3d 524 (2005) (analyzes cause-and-prejudice and procedural bars)
- People v. Leason, 352 Ill. App. 3d 450 (2004) (discussion of notice and standards for new petitions)