People v. Pruitt

2021 IL App (4th) 190598-U
CourtAppellate Court of Illinois
DecidedJuly 15, 2021
Docket4-19-0598
StatusUnpublished

This text of 2021 IL App (4th) 190598-U (People v. Pruitt) 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. Pruitt, 2021 IL App (4th) 190598-U (Ill. Ct. App. 2021).

Opinion

2021 IL App (4th) 190598-U Rule 23 filed July 15, 2021 NOTICE This Order was filed under Supreme Court Rule 23 and is NO. 4-19-0598 Modified upon denial of Rehearing October 13, 2021 not precedent except in the IN THE APPELLATE COURT limited circumstances allowed under Rule 23(e)(1). OF ILLINOIS

FOURTH DISTRICT

THE PEOPLE OF THE STATE OF ILLINOIS, ) Appeal from the Respondent-Appellee, ) Circuit Court of v. ) Vermilion County BRIAN E. PRUITT, ) No. 95CF493 Petitioner-Appellant. ) ) Honorable ) Thomas M. O’Shaughnessy, ) Judge Presiding.

JUSTICE STEIGMANN delivered the judgment of the court. Justices Cavanagh and Holder White concurred in the judgment.

ORDER

¶1 Held: The appellate court affirmed the trial court’s judgment because defendant was properly sentenced to life in prison.

¶2 In August 1996, the trial court sentenced the then 17-year-old defendant, Brian E.

Pruitt, to mandatory life in prison for murdering both of his grandparents in October 1995. In 2013,

defendant filed a postconviction petition in which he requested a new sentencing hearing pursuant

to Miller v. Alabama, 567 U.S. 460 (2012), because his mandatory life sentence for crimes

committed when he was a juvenile violated the eighth amendment of the United States

Constitution.

¶3 The trial court ultimately granted the petition and, in June 2019, conducted

defendant’s resentencing hearing. The court again sentenced defendant to life in prison.

¶4 Defendant appeals, arguing that (1) the trial court erred when it decided that the rule announced in Apprendi v. New Jersey, 530 U.S. 466 (2000), did not apply at defendant’s

resentencing hearing, (2) the trial court erred by sentencing defendant to life in prison after finding

him permanently incorrigible based upon the nature of the offenses but without finding he was

beyond rehabilitation, and (3) defendant received ineffective assistance of counsel because his

attorney (a) proceeded under the 1995 first degree murder sentencing statute and (b) later failed to

seek to proceed pursuant to the 2019 first degree murder sentencing statute. We disagree and

affirm.

¶5 I. BACKGROUND

¶6 A. The Charges

¶7 In October 1995, the State charged defendant with six counts of first degree murder

pursuant to section 9-1(a)(1) of the Code of Criminal Procedure of 1961 (720 ILCS 5/9-1(a)(1)

(West 1994)) and two counts of first degree murder pursuant to section 9-1(a)(2) (id. § 9-1(a)(2)).

Generally, the charges alleged that defendant murdered both of his grandparents by stabbing them.

¶8 B. The Trial

¶9 Because the evidence at trial is not at issue in this appeal, we will summarize the

evidence only to the extent necessary to provide context for the issues this appeal raises.

¶ 10 Defendant’s mother, Karen Pruitt, lived with a man named Clyde Jones when

defendant was very young. Jones introduced Karen to drugs and physically abused her and

defendant. Jones would beat defendant and once stabbed Karen in front of defendant.

¶ 11 When defendant was six years old, Karen called the Illinois Department of Children

and Family Services (DCFS) and surrendered defendant to the agency’s foster care system. Less

than a year later, defendant’s grandparents, Roberta and Frank McNeely, learned defendant was

not being well cared for at the foster home and had defendant transferred to their care.

-2- ¶ 12 Defendant lived with his grandparents for several years. When defendant was

around 11 or 12 years old, he began to sneak out of his bedroom window and stay out late at night.

When defendant was 13 years old, his grandparents had him removed from their home. They sent

a police officer to pick defendant up from school and take him to DCFS because they did not want

him anymore.

¶ 13 Defendant was moved to several group foster homes but had significant problems.

Defendant sometimes tried to return to his grandparents’ home, but when he did so, he was not

allowed to stay. Eventually, defendant was admitted to a secure psychiatric facility in Illinois and

then transferred to a secure psychiatric facility in Arizona. Defendant described his placement in

the Arizona facility as “horrible” and said there were cockroaches and insects everywhere. When

defendant misbehaved, he was drugged and tied to a bed or locked in a closet. At one point, he

pulled a fire alarm in an attempt to run away, and he was charged with criminal damage to property.

Defendant was placed in juvenile detention in Arizona and was later transferred to a facility in

Texas. Defendant successfully completed his placement in Texas when he was 16 years old and

was then sent back to his grandparents’ home in Illinois.

¶ 14 Not long after defendant’s return to his grandparents’ home, he began to have

problems because he did not follow their rules. He drank alcohol, refused to follow curfew, refused

to go to school, and threatened his grandparents. DCFS began to discuss placing defendant in

another psychiatric hospital.

¶ 15 Ultimately, in October 1995, before defendant could be removed from his

grandparents’ home, he stabbed his grandparents one time each, killing them nearly instantly.

¶ 16 Shortly after the murders, the police arrested defendant. Keith Garrett, a Danville

Police Department officer, interviewed defendant and described him as “nonchalant” and that he

-3- did not “seem too concerned.” In the interview, defendant said that on the day of the murders, he

came home from school and met with Leta Pepper, a counselor contracted through DCFS.

Defendant became upset with Pepper because “she was giving him a hard time about going to

school and some other things.”

¶ 17 Another officer, Gene Woodard, assisted with the interview. Woodard confronted

defendant with the fact that his grandparents were dead and asked defendant what happened.

Defendant cried and admitted he killed both of his grandparents. He said he stabbed his

grandmother one time while she was asleep and waited about 15 to 20 minutes for his grandfather

to come home before stabbing him in the back. Defendant then cleaned up the house with some

towels and left, driving his grandfather’s car, to dispose of the knife and towels. The officers asked

defendant if he knew what he was doing was wrong. Defendant replied, “I didn’t know I was doing

it.” Defendant explained that he would not want to hurt his grandparents because they were all he

had.

¶ 18 The jury found defendant guilty of both murders. The trial court entered judgment

on both counts of first degree murder and later sentenced defendant to mandatory life in prison

because he had been convicted of murdering more than one person. See 730 ILCS

5/5-8-1(a)(1)(c)(2) (West 1994).

¶ 19 Defendant appealed, and this court affirmed the trial court’s judgment. People v.

Pruitt, No. 4-96-0722 (1997) (unpublished order under Illinois Supreme Court Rule 23). In 2001,

defendant filed his first postconviction petition alleging the trial court erred when it sentenced him

to life in prison based upon a finding that the murders were accompanied by brutal and heinous

behavior. The trial court dismissed the petition at the first stage of proceedings, concluding

defendant was sentenced to life in prison because he was convicted of murdering more than one

-4- person.

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Related

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