People v. Ybarra
2016 IL App (1st) 142407
Ill. App. Ct.2017Background
- In Feb 2009 Martin Ybarra (age 20) was convicted by a jury of three counts of first-degree murder for shooting and killing three teenagers near Bowen High School; he was the shooter.
- Police recovered an AK-style rifle hidden in family property; eyewitnesses (multiple disinterested witnesses and an accomplice-turned-witness) identified Ybarra in a photo array and lineup.
- Defense presented extensive mitigation evidence: poverty, family dysfunction, prenatal exposure, lead exposure, low IQ/developmental disabilities, poor school performance.
- Ybarra was sentenced to mandatory natural life under 730 ILCS 5/5-8-1(a)(1)(c)(ii) (mandatory life for offenders 17+ who murder more than one victim).
- At sentencing the trial court said it had reviewed mitigation, found no rehabilitative potential, and stated it would impose life even if it had discretion.
- On appeal Ybarra argued the mandatory natural life sentence violates the proportionate penalties clause of the Illinois Constitution because it barred consideration of mitigating evidence and foreclosed return to useful citizenship.
Issues
| Issue | Plaintiff's Argument (People) | Defendant's Argument (Ybarra) | Held |
|---|---|---|---|
| Whether mandatory natural life for multiple murders violates Illinois Constitution's proportionate penalties clause as applied to Ybarra | Statute is facially constitutional; legislature rationally balanced seriousness of multiple murders and rehabilitation interests; trial court considered mitigation and would have imposed life anyway | Mandatory sentence precludes meaningful consideration of mitigation and prevents chance of restoration to useful citizenship given Ybarra's youth and background | Affirmed: statute constitutional as applied; mandatory life did not "shock the moral sense" given Ybarra was the shooter of three unarmed teens and trial court reviewed mitigation and would have imposed life even with discretion |
| Whether Miller/Graham/Roper jurisprudence for juveniles extends to youthful adult offenders like Ybarra | Supreme Court juvenile precedents do not automatically apply to adults 18+; legislative classification is permissible | Ybarra (age 20) is a "youthful offender" and analogous reasoning should limit mandatory life without parole | Rejected: distinctions matter (Ybarra was adult shooter who pulled trigger repeatedly); Miller line does not compel relief here |
| Whether People v. House (2015) requires reversal because of Ybarra's age and background | House is distinguishable because that defendant was a lookout convicted under accountability theory | Ybarra argues House supports applying youthful-offender mitigation principles to young adults | Court distinguished House: Ybarra was the actual shooter, not an accomplice lookout, so House inapplicable |
| Whether the trial court failed to consider mitigation as requested | State: court did review mitigation, conducted balancing, and expressly stated it considered all factors | Ybarra: mandatory sentence prevented meaningful consideration; trial court record unclear | Court found record shows mitigation was read and considered; court explicitly would have given life even with discretion |
Key Cases Cited
- Roper v. Simmons, 543 U.S. 551 (holds Eighth Amendment bars death penalty for juvenile offenders)
- Graham v. Florida, 560 U.S. 48 (bars life without parole for juveniles for nonhomicide offenses; requires consideration of youth)
- Miller v. Alabama, 567 U.S. _ (requires individualized sentencing consideration for juvenile homicide offenders before imposing mandatory life without parole)
- People v. Miller, 202 Ill. 2d 328 (discusses Illinois proportionate penalties clause and legislative role in penalties)
- People v. House, 2015 IL App (1st) 110580 (applied youthful-offender reasoning to reverse mandatory life where defendant was a 19-year-old accomplice/lookout)
- People v. Gipson, 2015 IL App (1st) 122451 (found lengthy sentence unconstitutional as applied to juvenile with mental-health issues)