Citation: People v. Coty, 2020 IL 123972

Summary: In this case the Illinois Supreme Court reviewed the constitutionality of a 2006 mandatory life sentence imposed on an intellectually disabled man.  William Coty, 46 at the time of his offense, was convicted of predatory criminal sexual assault of a child, criminal sexual assault and aggravated criminal sexual assault and sentenced to a natural life sentence due to a prior sexual assault conviction.  The defendant argued that his statutory mandated life sentence due to a previous sexual assault conviction was a violation of the proportionate penalties clause of the Illinois Constitution, noting that his intellectual disability placed him at a similar developmental stage as an adolescent. In light of the Supreme Court’s decision in Miller, Coty’s counsel argued that a mandatory sentencing scheme that didn’t allow for evaluation of the attendant characteristics of intellectual disability in sentencing was a facial constitutional violation. The court ultimately rejected Coty’s arguments and held that the mandatory sentencing scheme was appropriate and the sentence was affirmed. With regards to the scientific evidence, the court noted: “The enhanced prospect that, as the years go by and neurological development occurs, deficiencies will be reformed—is not a prospect that applies to this intellectually disabled defendant, who was 46 years old when he committed this, his second sexual offense against a child. The rehabilitative prospects of youth do not figure into the sentencing calculus for him.” People v. Coty, 2020 IL 123972, ¶ 40

Key words:  Illinois, Proportionate Penalties Clause, Intellectual Disability, Miller v. Alabama, LWOP