Citation: People v. Suggs, 2020 IL App (2d) 170632

Summary: Defendant Montago E. Suggs was sentenced to 110 years in prison in 2007 after being found guilty of first degree murder, attempted murder, and attempted armed robbery in the state of Illinois. Suggs was 23 years old at the time he committed his crimes. The defendant filed for post-conviction relief in the trial court on the grounds his sentence violated the 8th amendment of the U.S. Constitution. In a 2012 court case, Miller v Alabama, the Supreme Court ruled that even juveniles convicted of homicide cannot be automatically sentenced to life without the possibility of parole. Suggs argued that because emerging brain science suggests that the brain continues developing until someone’s mid twenties, Miller should also be applied to Suggs’ case. The trial court denied his application, and on this appeal, the Illinois Appellate Court affirmed the denial, holding that Suggs did not “exhibit signature qualities of youth that require juveniles to be treated differently from adults” and, therefore, upheld Sugg’s sentence.

Key words: Eighth Amendment, Miller v. Alabama, adolescent brain science, emerging adults, Illinois