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People v. Wilson (May 2023)

RULING: Wilson’s de facto sentence under the theory of accountability violates the Eighth Amendment, but not Illinois' proportionate penalties mandate - further proceedings are required.

The Illinois Supreme Court ruled that the petitioner did not establish prejudice for his 8th Amendment claim; the court denied leave to file a successive post-conviction petition. This case overruled People v. Holman, which previously held that a juvenile could only be sentenced to discretionary life without parole if the court determined the youth was “permanently incorrigible,” or, in other words, incapable of rehabilitation. This case will go back to an Appellate Court to determine if the petitioner’s claim under the Illinois Constitution’s Proportionate Penalties Clause is still valid.

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