People v. Reyes

2025 IL App (1st) 241172-U
Procedural entryThis page is a short order in People v. Reyes. Read the opinion of the Court — 467 Ill. Dec. 674
Appellate Court of Illinois·Decided September 25, 2025·No. 1-24-1172·Unpublished

Opinion

2025 IL App (1st) 241172-U No. 1-24-1172 Order filed September 25, 2025 Fourth 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. 02 CR 27512 ) ANDRES REYES, ) Honorable ) Marc W. Martin, Defendant-Appellant. ) Judge Presiding.

PRESIDING JUSTICE NAVARRO delivered the judgment of the court. Justices Lyle and Ocasio concurred in the judgment.

ORDER

¶1 Held: We affirm the circuit court’s grant of the State’s motion to dismiss where the defendant’s as-applied proportionate penalties clause claim is barred by res judicata and he failed to make a substantial showing that his trial counsel was ineffective during his sentencing hearing.

¶2 Following a jury trial, defendant Andres Reyes was found guilty of first-degree murder and

attempted first-degree murder, and sentenced to 75 years’ imprisonment. This court affirmed his

sentence on direct appeal. People v. Reyes, No. 1-04-3342 (2006) (unpublished order under Illinois

Supreme Court Rule 23). Several years later, Reyes filed a postconviction petition claiming that No. 1-24-1172

his sentence was unconstitutional, as applied to him, under the proportionate penalties clause of

the Illinois Constitution (Ill. Const. 1970, art. I, § 11) and his trial counsel provided ineffective

assistance during his sentencing hearing. On the State’s motion, the circuit court dismissed his

petition. Reyes now appeals that dismissal and contends that his petition should have advanced to

an evidentiary hearing where he made a substantial showing that his sentence was unconstitutional

and his trial counsel was ineffective during sentencing. For the reasons that follow, we affirm.

¶3 I. BACKGROUND

¶4 A. Trial and Direct Appeal

¶5 A grand jury indicted Reyes with multiple counts of first-degree murder and attempted

first-degree murder in connection with a December 2000 shooting death of Arnulfo Munoz. At the

time of the shooting, Reyes was 19 years old. The case proceeded to a jury trial, where the evidence

showed there had been an altercation outside Reyes’ home between himself, a former member of

the Latin Kings gang, and members of the Surenos 13s, a rival gang, which included Munoz and

Emigdio Hernandez. Following the altercation, Reyes obtained a firearm and chased after

members of the Surenos 13s, eventually locating Munoz and Hernandez. Reyes pointed the firearm

at Hernandez and pulled the trigger, but it did not discharge. Reyes then pointed the firearm at

Munoz and shot him dead. Reyes, meanwhile, fled to Mexico. Several months later, the police

arrested him in Texas, and he confessed to the shooting, though he did express remorse. The jury

found Reyes guilty of first-degree murder of Munoz and attempted first-degree murder of

Hernandez.

¶6 The case continued to sentencing. According to Reyes’ presentence investigative report,

he reported that his childhood was “good,” he never was the victim of abuse or neglect, and he had

a good relationship with both of his parents. According to Reyes, he was involved with the Latin

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Kings, beginning at 11 years old, but later left the gang. Reyes stated that he attended high school,

but was expelled during his freshman year due to gang activity. Although he re-enrolled, he later

dropped out. The presentence investigative report revealed that Reyes had a three-year-old

daughter and no criminal background. During Reyes’ sentencing hearing, the State introduced a

victim impact statement from Munoz’s fiancée, who discussed the impact that his death had on

her and their daughter. However, she remarked that she did not hate Reyes, and she felt sympathy

for his family, including his own daughter, who was also losing someone. Reyes’ trial counsel did

not present any evidence in mitigation, and during argument, counsel highlighted Reyes’

presentence investigative report and noted his current age. Yet, counsel focused on Reyes’ lack of

a criminal history and the sympathy shown by Munoz’s fiancée toward Reyes’ family.

¶7 Following the parties’ arguments, the trial court observed Reyes’ background, as elicited

in the presentence investigative report, and noted his “good home” with no abuse, but his

tumultuous high school experience. Although the court acknowledged Reyes’ lack of a criminal

background, it asserted that he chased Munoz and Hernandez through residential areas of Palatine,

Illinois, before ultimately killing Munoz. The court believed that a serious sentence was necessary

to deter others from using residential neighborhoods as “hunting grounds” in addition to the

offenses being completely “senseless.” The court accordingly sentenced Reyes to 65 years’

imprisonment for first-degree murder, which included 40 years for the murder and an additional

statutory enhancement of 25 years for personally discharging a firearm that caused death, and 10

years’ imprisonment for attempted first-degree murder. The court asserted that the sentences had

to be served consecutively for a total of 75 years’ imprisonment.

¶8 Reyes appealed and only challenged his sentence as being excessive, and thus an abuse of

discretion, in light of his age at the time of the offenses, his lack of a criminal background, his

-3- No. 1-24-1172

rehabilitative potential and his expression of remorse. People v. Reyes, No. 1-04-3342 (2006)

(unpublished order under Illinois Supreme Court Rule 23). This court found that the trial court did

not abuse its discretion in sentencing Reyes because it did not ignore his rehabilitative potential,

specifically noted his lack of a criminal background and sentenced him, in part, based on the

seriousness of the offenses. Id. This court accordingly affirmed his sentence. Id.

¶9 B. Postconviction Proceedings

¶ 10 In August 2020, Reyes filed a motion for leave to file a successive postconviction petition

and attached the purported successive petition. The circuit court found that Reyes had never filed

an initial petition and in turn, treated the allegedly successive filing as an initial petition. In relevant

part, Reyes’ petition claimed that his 75-year sentence was unconstitutional, as applied to him,

under the proportionate penalties clause of the Illinois Constitution (Ill. Const. 1970, art. I, § 11).

Reyes argued that scientific studies demonstrated that the brain continued to develop beyond the

age of 18, and thus, his 19-year-old brain was still developing and similar to that of a juvenile

when he committed his offenses. According to Reyes, this fact made him less culpable for the

offenses than a fully developed adult and provided him with enhanced rehabilitative potential.

¶ 11 Reyes attached various evidence to his petition as support, including multiple articles on

the development of the brain in emerging adults and a report prepared by Dr. James Garbarino, a

developmental psychologist associated with Loyola University Chicago, that provided a

developmental history of Reyes based on his social background. Dr. Garbarino noted numerous

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