People v. Jenkins

2025 IL App (1st) 230177-U
CourtAppellate Court of Illinois
DecidedMarch 6, 2025
Docket1-23-0177
StatusUnpublished

This text of 2025 IL App (1st) 230177-U (People v. Jenkins) is published on Counsel Stack Legal Research, covering Appellate Court of Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
People v. Jenkins, 2025 IL App (1st) 230177-U (Ill. Ct. App. 2025).

Opinion

2025 IL App (1st) 230177-U No. 1-23-0177 Order filed March 6, 2025 Third Division

NOTICE: This order was filed under Supreme Court Rule 23 and is not precedent except in the limited circumstances allowed under Rule 23(e)(1). ______________________________________________________________________________ IN THE APPELLATE COURT OF ILLINOIS FIRST DISTRICT ______________________________________________________________________________ THE PEOPLE OF THE STATE OF ILLINOIS, ) Appeal from the ) Circuit Court of Plaintiff-Appellee, ) Cook County. ) v. ) No. 07 CR 9982 ) TERREL JENKINS, ) Honorable ) Neera Walsh, Defendant-Appellant. ) Judge, presiding.

JUSTICE REYES delivered the judgment of the court. Justices Martin and D.B. Walker concurred in the judgment.

ORDER

¶1 Held: Vacated and remanded with instructions. Trial court erred in resentencing defendant as adult without permitting discretionary transfer hearing.

¶2 Following a jury trial, defendant Terrel Jenkins was found guilty of murder (720 ILCS 5/9-

1(a)(1) (West 2002)) while personally discharging a firearm that proximately caused death to

another person. At the time of the offense, defendant was 15 years old. Defendant was sentenced

to 25 years’ imprisonment for murder and an additional 25 years’ imprisonment for the firearm No. 1-23-0177

enhancement, for a total of 50 years in prison. This court affirmed. People v. Jenkins, 2013 IL App

(1st) 103006-U, appeal denied, vacated, No. 115979 (Ill. Mar. 25, 2020) (supervisory order).

Later, pursuant to the Illinois Supreme Court’s supervisory order, this court entered an agreed

order vacating defendant’s sentence and remanding to the circuit court for a new sentencing

hearing. People v. Jenkins, No. 1-10-3006 (Sept. 14, 2020) (dispositional order).

¶3 On remand, the circuit court denied defendant’s motion to transfer the case to juvenile court

where the State could “petition for a discretionary transfer *** to adult criminal court,” and

subsequently imposed 20 years’ imprisonment for murder and 25 years’ imprisonment for the

firearm enhancement for a total of 45 years in prison. On appeal, defendant argues, and the State

agrees, that the circuit court erred in denying defendant’s motion to transfer to juvenile court. He

also argues his sentence was excessive. We vacate the sentence and remand with instructions.

¶4 We set forth only the facts necessary to understand the issue on appeal.

¶5 In May 2007, the State charged defendant with multiple counts of murder for the September

15, 2002, shooting death of Lloyd Ware. Because defendant was 15 years old at the time of the

offense, he was prosecuted as an adult pursuant to the automatic transfer provision then in effect

(705 ILCS 405/5-130(1)(a) (West 2006)), which provided in part that 15- and 16-year-old

defendants charged with murder were to be prosecuted under the Criminal Code of 1961

(720 ILCS 5/1-1 et seq. (West 2006)).

¶6 In his first direct appeal, defendant challenged the sufficiency of the evidence and certain

evidentiary rulings, argued the automatic transfer provision was unconstitutional, and contended

that his 50-year sentence was excessive. We affirmed. Jenkins, 2013 IL App (1st) 103006-U, ¶ 2.

In September 2013, the Illinois Supreme Court initially granted defendant’s petition for leave to

-2- No. 1-23-0177

appeal. People v. Jenkins, No. 115979 (Ill. Sept. 25, 2013) (supervisory order). In March 2020,

however, our supreme court reversed and denied the petition, but exercised its supervisory

authority to order this court to vacate the direct appeal decision and “consider the effect of ***

People v. Buffer, 2019 IL 122327, on the issue of whether defendant’s sentence constitutes a de

facto life sentence in violation of the Eighth Amendment and Miller v. Alabama,

567 U.S. 460 (2012), and determine if a different result is warranted.” Jenkins, No. 115979 (Ill.

Mar. 25, 2020) (supervisory order).

¶7 On September 14, 2020, this court vacated defendant’s sentence and remanded to the

circuit court for a new sentencing hearing in compliance with Miller, Buffer, People v. Holman,

2017 IL 120655, overruled by People v. Wilson, 2023 IL 127666, and section 5-4.5-105 of the

Unified Code of Corrections (730 ILCS 5/5-4.5-105 (West 2020)). Jenkins, No. 1-10-3006 (Sept.

14, 2020) (dispositional order).

¶8 While defendant’s appeal pended before the Illinois Supreme Court, the Juvenile Court Act

was amended. See Pub. Act 99-258, § 5 (eff. Jan. 1, 2016) (amending 705 ILCS 405/5-130(1)(a)).

Under the amended statute, a 15-year-old accused of murder is not automatically transferred to

adult court. Id. Instead, the State can file a petition under section 5-130(1)(c)(ii) of the Juvenile

Court Act (705 ILCS 405/5-130(1)(c)(ii) (West 2020)) for the defendant to be sentenced in adult

court. Further, our supreme court held that the amendment to section 5-130 applies retroactively

to cases pending trial. People ex rel. Alvarez v. Howard, 2016 IL 120729, ¶ 28; see also People v.

Hunter, 2017 IL 121306, ¶ 43 (clarifying that the amendment applies to cases that are still in “trial

court proceedings” and not cases “pending in the appellate court”).

-3- No. 1-23-0177

¶9 Defendant filed a motion to transfer the case to juvenile court where the State could

“petition for a discretionary transfer *** to adult criminal court,” asserting the Illinois Supreme

Court’s holding in Howard applied to his case. The circuit court denied the motion, finding that

transfer to juvenile court was beyond the appellate court’s mandate and would be impractical

because defendant was over 21 years old. At resentencing, defendant received 45 years in prison.

The court denied defendant’s motion to reconsider, which did not include the claim that the

amended section of the Juvenile Court Act should apply to his case.

¶ 10 On appeal, defendant first contends that the circuit court erred in denying his motion to

transfer the case to juvenile court and that the amended version of section 5-130 of the Juvenile

Court Act should apply to his case for resentencing.

¶ 11 Defendant argues that once his case was remanded for resentencing, his trial proceedings

had not concluded because a conviction is not final until after sentencing. See People v. Vara,

2018 IL 121823, ¶ 14; People v. Clark, 2020 IL App (1st) 182533, ¶ 70; People v. Price, 2018 IL

App (1st) 161202, ¶ 20. Thus, according to defendant, the amendments to the juvenile-sentencing

law should apply to him for resentencing. Clark, 2020 IL App (1st) 182533, ¶ 70; Price, 2018 IL

App (1st) 161202, ¶ 22 (amended section 5-130 applied to sentencing hearing held after

amendment became law). He requests the same relief granted in Clark, 2020 IL App (1st) 182533,

¶ 86: vacate his sentence and remand the case to allow the State to file a petition under section 5-

130(1)(c)(ii) for adult sentencing. The State agrees.

¶ 12 Defendant’s claim was not included in his motion to reconsider sentence. Thus, the issue

was forfeited and may not be considered on appeal except under plain error review. Ill. S. Ct. R.

615(a) (eff. Jan.

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Related

People v. Bannister
902 N.E.2d 571 (Illinois Supreme Court, 2008)
People v. Hicks
693 N.E.2d 373 (Illinois Supreme Court, 1998)
Miller v. Alabama
132 S. Ct. 2455 (Supreme Court, 2012)
People ex rel. Alvarez v. Howard
2016 IL 120729 (Illinois Supreme Court, 2017)
People v. Hunter
2017 IL 121306 (Illinois Supreme Court, 2017)
People v. Fort
2017 IL 118966 (Illinois Supreme Court, 2018)
People v. Vara
2018 IL 121823 (Illinois Supreme Court, 2019)
People v. Buffer
2019 IL 122327 (Illinois Supreme Court, 2020)
People v. Clark
2020 IL App (1st) 182533 (Appellate Court of Illinois, 2020)
People v. Price
2018 IL App (1st) 161202 (Appellate Court of Illinois, 2018)
People v. Wilson
2023 IL 127666 (Illinois Supreme Court, 2023)

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Bluebook (online)
2025 IL App (1st) 230177-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-jenkins-illappct-2025.