People v. Watson

Illinois Appellate Court, First District, Third Division · 2021 · Criminal Law

201 N.E.3d 63

Updated July 19, 2026

crimlawfelony murderaccountabilityjuvenile due processsentencingdue processjuvenilescommon design

Facts

At age 17, defendant helped plan a robbery of Sherman Horton with Lavell Blanchard and lured Horton into position while texting Blanchard to come rob him. Blanchard arrived armed, approached Horton's car with another man, and shot Horton through the window during the robbery attempt; Horton died. Defendant later admitted she had set up the robbery and had planned it with Blanchard in advance, though she said Horton was not supposed to be shot. The trial court found that defendant had planned an armed robbery and convicted her of first degree murder under felony-murder and accountability theories.

Issue

Does substantive due process bar the State from convicting a juvenile of first degree murder under felony-murder or common-design accountability when the juvenile neither killed nor intended a killing to occur? If not, was defendant's 25-year sentence excessive?

Rule

Under due process, a state criminal statute is invalid only if it offends a principle of justice so rooted in the traditions and conscience of the people as to be fundamental; defendant identified no such historical principle exempting juveniles from felony-murder or accountability liability when they neither killed nor intended to kill. In Illinois, traditional felony murder is concerned with the intent to commit the underlying forcible felony, not intent to kill or foreseeability, and common-design accountability likewise turns on participation in the planned offense, not intent to murder or reasonable foreseeability.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Peoria, 16-year-old Maya Torres agrees to help her cousin rob a man who is arriving to buy a laptop. Maya sends the victim the meeting location and keeps him talking in the parking lot while her cousin approaches with a knife and fatally stabs the victim during the attempted robbery.

Maya argues that substantive due process bars her murder conviction because she is a juvenile and did not kill or intend anyone to die. What is the strongest response?

Explanation. The majority held that due process does not create a special juvenile exemption from felony-murder liability when the juvenile neither killed nor intended a killing. In traditional Illinois felony murder, the relevant intent is the intent to commit the underlying forcible felony, not intent to kill, and foreseeability is not an element. Thus Maya's juvenile status and claimed lack of homicidal intent do not establish a substantive due process bar. (Derived from People v. Watson (n.d.).)