People v. Williams
107 N.E.3d 254
Ill. App. Ct.2018Background
- In May 1994, 19‑year‑old Cordell Williams drove a car and opened the trunk at the direction of a passenger, David Evans (17), who retrieved a gun and fatally shot two people; Williams drove Evans away afterwards.
- Williams was convicted of two counts of first‑degree murder under Illinois’s accountability statute and, in August 1995, sentenced to mandatory natural life without parole because he was convicted of multiple murders.
- Williams pursued extensive postconviction and collateral litigation over many years; after Miller v. Alabama (2012) he sought relief arguing his mandatory life sentence was unconstitutional as applied and sought leave to file a second successive postconviction petition.
- The trial court denied leave, finding Miller inapplicable because Williams was 19 at the time of the offenses; Williams appealed the denial.
- The appellate court found Williams satisfied the "cause" prong (Miller was decided after his convictions) and held he satisfied the "prejudice" prong because his youth (age 19), limited participation, and lack of sentencing discretion made the mandatory life term disproportionate as applied.
- Remedy: the court vacated Williams’s sentence, remanded for a new sentencing hearing instructing the court to consider mitigating factors (especially youth and limited role), and directed that if resentenced to a term of years the mittimus be amended to reflect 441 days of presentence credit.
Issues
| Issue | People’s Argument | Williams’s Argument | Held |
|---|---|---|---|
| Whether leave to file a second successive postconviction petition should be granted based on Miller | Denied: Miller applies only to those under 18; Williams was 19, so no prejudice | Miller and related authority show mandatory life without parole is unconstitutional as applied to a 19‑year‑old with limited participation | Granted: Williams satisfied cause and prejudice; denial of leave was error because sentence is unconstitutional as applied |
| Whether mandatory life without parole violated proportionate‑penalties clause as applied | Mandatory multiple‑murders statute valid; accountability focus is on the homicide, not role; Taylor bars facial challenge | As‑applied challenge: youthful 19‑year‑old brain development and limited role make mandatory life disproportionate | Held unconstitutional as applied; remand for resentencing with discretion to consider youth and role |
| Whether Williams is entitled to presentence custody credit (441 days) if resentenced to a term of years | No credit necessary while sentence is natural life; credit only applies if resentenced to a term of years | If resentenced to a term of years, Williams is entitled to 441 days of credit for presentence custody | Court directed that if resentenced to a term of years, the mittimus be amended to reflect 441 days’ credit |
Key Cases Cited
- Miller v. Alabama, 567 U.S. 460 (recognizes mandatory life without parole for juveniles violates Eighth Amendment)
- Roper v. Simmons, 543 U.S. 551 (holds death penalty unconstitutional for offenders under 18; discusses differences between juveniles and adults)
- People v. Miller (Leon Miller), 202 Ill. 2d 328 (Illinois Supreme Court: mandatory natural life for multiple murders may violate proportionate‑penalties clause as applied)
- People v. Sharpe, 216 Ill. 2d 481 (proportionate‑penalties clause standard; penalty unconstitutional if so disproportionate it shocks community moral sense)