People v. White
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In 1999, Sedrick White, then 20 years old, entered a blind guilty plea to one count of first-degree murder and was sentenced to 40 years in prison by the Cook County circuit court. Over 20 years later, White filed a pro se petition for postjudgment relief under section 2-1401(f) of the Code of Civil Procedure, arguing that his 40-year sentence constituted a de facto life sentence in violation of the Eighth Amendment of the U.S. Constitution and the proportionate penalties clause of the Illinois Constitution. The circuit court denied the petition, stating that the sentence did not violate the Eighth Amendment or the proportionate penalties clause.
White appealed the circuit court's decision, arguing that his 40-year sentence violated the proportionate penalties clause. The appellate court affirmed the circuit court's decision, holding that White's guilty plea waived any potential constitutional claim regarding his sentence. The appellate court also found that the circuit court did not err in failing to recharacterize White's section 2-1401 petition as a petition under the Post-Conviction Hearing Act.
The Supreme Court of Illinois reviewed the case and agreed with the parties that White's blind guilty plea did not waive his constitutional challenge to his sentence. The court clarified that a defendant who enters a blind guilty plea, with no agreement as to the sentence, does not waive the right to challenge the sentence. However, the court found that White's 40-year sentence was not a de facto life sentence and was not "wholly disproportionate to the offense as to shock the moral sense of the community." The court concluded that White failed to state a meritorious claim that his sentence violated the proportionate penalties clause and affirmed the judgments of the appellate court and the circuit court.
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