People v. Brown

Summary

The court held that the 2021 amendment imposing an age requirement for habitual-criminal sentencing does not apply retroactively to invalidate Brown's 1995 natural-life sentence and did not clarify the law in effect when he was sentenced. The court also held that Brown's claim was cognizable under the Post-Conviction Hearing Act because an allegedly unauthorized sentence could implicate constitutional due process, but the claim failed because the amendment did not affect his sentence. The appellate court's judgment was reversed, and the circuit court's denial of leave to file a successive postconviction petition was affirmed.