The Supreme Court of Illinois ruled that a defendant retains the right to challenge his sentence when he enters a “blind” guilty plea, i.e., a plea that does not specify the sentence as part of the plea.

Background

Sedrick White admitted to fatally shooting Arnel Adamore in August 1998 while he was working security for a drug operation at age 20. He was charged with three counts of first-degree murder and one count of home invasion.

After a plea hearing conference, White rejected the offered plea deal and expressed his desire to simply plead guilty to first-degree murder. The court and the State accepted his plea, so the State dropped the remaining counts. 

White was sentenced to 40 years in prison, and the court admonished him regarding his appeal rights. About 11 days later, on its own motion, the court readmonished him, stating “I asked that the case be brought into court and [petitioner] be brought into court because I believe since this was a blind plea that I—he was improperly given the wrong admonitions with respect to after the plea.” Specifically, the court advised that if he wanted to challenge his sentence, he “must move to withdraw the plea of guilty, also or you must file a motion for reconsideration of that sentence within 30 days of today.”

White filed a timely motion to reconsider his sentence, claiming it was excessive in light of his background and other relevant factors. The court denied the motion, and he did not appeal.

Approximately 20 years later, in 2019, White filed a pro se petition for post-judgment relief pursuant to § 2-1401(f) of the Code (735 ILCS 5/2-1401(f)). He argued that “his 40-year sentence constituted a de facto life sentence in violation” of the Eighth Amendment of the United States Constitution and the proportionate penalties clause of the Illinois Constitution (Ill. Const. 1970, art. I, § 11). In particular, he argued that “changes in the law since his guilty plea, including case law recognizing that young adults should be afforded the same considerations as juvenile offenders at sentencing, established ‘cause’ for his claim.” Much of the recent case law he cited was based on research in neurology that shows a human brain is not fully formed until around age 25 and that executive decision-making is one of the last things to fully develop.

The State failed to respond to White’s petition, leaving the circuit court to make a decision without advisement or objection. The court denied his application, ruling that he failed to exercise diligence by presenting his claim so late and rejecting the proportionality claim by noting that a 40-year sentence is not a de facto life sentence for a 20-year-old.

On appeal, the appellate court upheld the denial but also concluded that White’s plea agreement foreclosed any challenge to his sentence. The appellate court reasoned that White voluntarily and knowingly entered a guilty plea, which waived all constitutional errors, including possible future changes in the law. People v. Jones, 190 N.E.3d 731 (Ill. 2021); People v. Aceituno, 216 N.E.3d 237 (Ill. App. Ct. 2022). It also noted that “Aceituno clearly states the type of plea is irrelevant.”

Analysis

On review, the Illinois Supreme Court also upheld the judgment of the circuit court denying White’s petition but reversed the ruling of the appellate court regarding a blind guilty plea constituting a waiver in challenging a sentence. 

The Court noted that when a defendant knowingly and voluntarily enters a “fully negotiated plea agreement,” he waives any sentencing challenges. Citing Jones, the Court explained that by entering into a fully negotiated plea agreement, a defendant waives any claim of error because it is well settled that a voluntary guilty plea waives all “non-jurisdiction errors or irregularities, including constitutional ones.” It further explained that “plea agreements are contracts, and principles of waiver apply equally to them. Entering into a contract is generally ‘a bet on the future.’ ‘[A] classic guilty plea permits a defendant to gain a present benefit in return for the risk that he may have to [forgo] future favorable legal developments.’” Jones. 

However, when there is no valid plea agreement in place, a “defendant manifestly cannot be breaching such a nonexistent agreement by arguing that the sentence which the court imposed was excessive.” People v. Lumzy, 730 N.E.2d 20 (Ill. 2000). Consequently, the contract principles that bar any sentencing challenge when there is a fully negotiated plea agreement do not apply when there is no valid plea agreement, according to the Court. Id. Thus, the Court concluded that “when a defendant enters an open or ‘blind’ guilty plea where there is no agreement as to sentence, the defendant is not precluded from challenging his sentence.” See People v. Johnson, 129 N.E.3d 1239 (Ill. 2019). 

Additionally, the Court instructed that to the extent Aceituno “suggests that a defendant who enters a knowing and voluntary guilty plea that contains no agreement as to sentence waives a constitutional challenge to his sentence, it is in error and overruled.”

The Court stated that the foregoing conclusion is further reinforced by the clear language of Illinois Supreme Court Rule 604(d), which states: “No appeal shall be taken upon a negotiated plea of guilty challenging the sentence as excessive unless the defendant, within 30 days of the imposition of sentence, files a motion to withdraw the plea of guilty and vacate the judgment. For purposes of this rule, a negotiated plea of guilty is one in which the prosecution has bound itself to recommend a specific sentence, or a specific range of sentence, or where the prosecution has made concessions relating to the sentence to be imposed and not merely to the charge or charges then pending.”

Turning to the present case, the Court noted that White knowingly and voluntarily entered a guilty plea, but it was a blind plea with no agreement or concession regarding the sentence. Thus, the Court ruled that he “did not waive any constitutional challenge to his sentence” because White’s blind plea never mentioned the sentence for the crime to which he agreed to plead guilty, so there was no agreement to breach when he ultimately challenged the legitimacy of his sentence.

As for the substance of his claim, the Court cited People v. Hilliard, 234 N.E.3d 668 (Ill. 2023), in which an 18-year-old, under similar circumstances to White’s, was sentenced to 40 years in prison, which was upheld on appeal. Thus, the Court ruled that White’s 40-year prison sentence was proportional to his offense, so he failed to state a meritorious claim.

Conclusion

Accordingly, the Court affirmed the judgment of the appellate court on other grounds and affirmed the judgment of the circuit court. See: People v. White, 2025 Ill. LEXIS 13 (2025).   

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