People v. Ramirez

2023 IL App (3d) 200470-U
CourtAppellate Court of Illinois
DecidedMarch 21, 2023
Docket3-20-0470
StatusUnpublished

This text of 2023 IL App (3d) 200470-U (People v. Ramirez) 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. Ramirez, 2023 IL App (3d) 200470-U (Ill. Ct. App. 2023).

Opinion

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).

2023 IL App (3d) 200470-U

Order filed March 21, 2023 ____________________________________________________________________________

IN THE

APPELLATE COURT OF ILLINOIS

THIRD DISTRICT

THE PEOPLE OF THE STATE OF ) Appeal from the Circuit Court ILLINOIS, ) of the 10th Judicial Circuit, ) Peoria County, Illinois, Plaintiff-Appellee, ) ) Appeal No. 3-20-0470 v. ) Circuit No. 18 CF 697 ) JOSE GUADALUPE RAMIREZ, ) Honorable ) Katherine S. Gorman, Defendant-Appellant. ) Judge, Presiding. ____________________________________________________________________________

JUSTICE DAVENPORT delivered the judgment of the court. Presiding Justice Holdridge and Justice Peterson concurred in the judgment. ____________________________________________________________________________

ORDER

¶1 Held: The trial court’s imposition of a mandatory life sentence on a 21-year-old defendant was not unconstitutional as applied to him, and the trial court did not err in denying defendant’s request to appoint an expert for sentencing proceedings or his request to conduct an evidentiary hearing. Affirmed.

¶2 The trial court convicted defendant of two counts of first degree murder (720 ILCS 5/9-

1(a)(1) (West 2018)) for the murders of his adoptive parents and sentenced him to mandatory life

imprisonment without parole (730 ILCS 5/5-8-1(a)(1)(c)(ii) (West 2020)). Defendant raises three

arguments on appeal. First, he argues his mandatory life sentence is unconstitutional as applied to him, alleging the court failed to consider his youth, traumatic and abusive upbringing, mental

health issues, and potential for rehabilitation. Second, defendant argues the court erred in refusing

to appoint an expert for sentencing proceedings, which precluded him from presenting evidence

to support his as-applied constitutional challenges. Third, he argues the court erred in denying his

as-applied constitutional challenges without allowing him to develop the record pursuant to People

v. Harris, 2018 IL 121932. His second and third arguments are made in the alternative to his first

argument if we find the record is insufficient to rule on his first argument. We affirm.

¶3 I. BACKGROUND

¶4 On October 28, 2018, defendant called 911 to report his parents missing and that someone

had broken into their house. Police entered the home and saw blood throughout. The television

was missing from the living room. Dresser drawers and jewelry boxes were open in the parent’s

bedroom. Police noted large bloodstains on the floor of the bedroom and all sheets and bedding

had been removed from the bed. Defendant later confessed to police that he and his codefendant

had snuck into the house, where defendant then maced his parents, hit them over the head with a

bat, and stabbed them in the stomach and throat. They wrapped the bodies in a tent and a tarp,

loaded them into his father’s car, and threw them off a bridge.

¶5 Defendant led police to the purported dump site in the Kewanee area, approximately 45

minutes away from the house. Police did not find the bodies there. The bodies were found two

days later in the Spoon River, 12 minutes away from the house. The victims were wearing pajamas.

The cause of death for both victims was multiple blunt-force and sharp-force injuries. Defendant’s

father had bruises all over his torso and head area, stab wounds to the torso, slice marks to the

throat, skin tears in the head, and his right ear was destroyed. Defendant’s mother had a single stab

wound under her right armpit, multiple stab wounds or slices on her throat, and skin tears on the

2 top of her head. The coroner’s autopsy revealed the time between onset of injuries and death was

minutes.

¶6 Police recovered the missing television and other items in the crawlspace at defendant’s

friend’s house where defendant had been staying. While being interviewed at the station, defendant

told police “the why” was not important. He felt remorse for getting his friend involved, but not

for the murders themselves, because he felt that he could not live while his parents were still alive.

He was 21½ years old at the time of the murders.

¶7 Before trial, Dr. Terry Killian evaluated defendant’s fitness to stand trial and his sanity at

the time of the offense. He reported the evaluation was thorough, as defendant was facing a

possible sentence of life in prison without parole. Defense counsel did not provide the State or trial

court with a copy of Dr. Killian’s report prior to trial. The report included the following history.

Defendant was removed from his biological mother’s care when he was three years old due to

physical and sexual abuse by the mother’s boyfriends. He was abused in foster care. The victims

adopted defendant when he was eight years old. Defendant began seeing a therapist shortly after

the adoption and continued to see her until two months before the murders. The therapist diagnosed

him with reactive attachment disorder (RAD). Her therapy notes specified a concern for his

adoptive mother’s safety at home. Defendant attended a residential therapeutic high school out of

state, returning to Illinois for his senior year. Dr. Killian noted defendant’s childhood was fraught

with abuse but concluded that defendant was fit to stand trial and sane at the time of the offense.

¶8 The trial court found defendant guilty of two counts of first degree murder after a three-

day bench trial. After the trial, defendant filed several posttrial motions: (1) a motion asking the

court to appoint a mental health expert for sentencing; (2) a motion to declare the mandatory

natural life imprisonment statute (730 ILCS 5/5-8-1 (West 2020)) unconstitutional under the

3 United States and Illinois constitutions as applied to defendant, due to his age and mental health

issues; and (3) an amended motion requesting a hearing pursuant to Harris, 2018 IL 121932, and

asking the court to appoint Dr. Killian to prepare a report and testify at the requested hearing. When

these motions were denied, defendant filed a motion for a new trial, averring that the court erred

in denying defendant’s request for an expert for sentencing purposes.

¶9 Defendant sought an expert to evaluate defendant’s presentence investigation report (PSI)

and history for the purpose of mitigation. The State argued that Dr. Killian had already examined

defendant, and although the State was never provided a copy of the report, defense counsel was in

possession of the psychiatric evaluation and presumably would call Dr. Killian to testify at

sentencing if the report contained mitigating information. Defendant argued Dr. Killian’s purpose

for initially evaluating defendant was not for mitigation, but for fitness and sanity. He wanted to

find a qualified individual to evaluate for mitigation at a more economical rate than Dr. Killian.

Defendant later asked the court to appoint Dr. Killian, as Dr. Killian could probably use his report

for the purposes of mitigation, and it would likely be quicker and cheaper than hiring a different

expert. He asked for funds not to exceed $3000. The State objected because Dr. Killian already

wrote a report that the State had not seen.

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Bluebook (online)
2023 IL App (3d) 200470-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-ramirez-illappct-2023.