People v. Clark

Summary

The court affirmed denial of leave to file a successive postconviction petition challenging Robert Clark's 90-year murder sentence under the Illinois proportionate penalties clause. Clark could not establish cause because his intellectual-disability and youth-based sentencing arguments were available and substantially raised in earlier proceedings, and he could not establish prejudice because the sentence was discretionary and the sentencing court considered his impairments and mitigation. The court also concluded that the Miller-based reasoning concerning transient youth did not apply to Clark's permanent, untreatable impairments or otherwise establish a constitutional defect.