People v. Gates

── People v. Gates ── Court: Appellate Court of Illinois Date: May 15, 2026 Category: General 2026 IL App (1st) 211422-B No. 1-21-1422 Opinion Filed May 15, 2026 Sixth Division ______________________________________________________________________________ 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. 17 CR 09924 ) QUINTON GATES, ) Honorable ) Charles P. Burns, Defendant-Appellant. ) Judge, presiding. JUSTICE HYMAN delivered the judgment of the court, with opinion. Justices Pucinski and Gamrath concurred in the judgment and opinion. OPINION ¶1 Before imposing a sentence, the Illinois Constitution requires the trial court to weigh the seriousness of the offense against the defendant’s rehabilitative potential. Quinton Gates argues trial counsel undermined that balance by asking for a juvenile-style sentence while conceding that the trial court lacked authority to sentence him below the statutory minimum. We agree that counsel erred, but on this record, Gates cannot show prejudice. ¶2 Consistent with People v. Spencer, 2025 IL 130015, the record contains no factual basis to apply the science underlying Miller v. Alabama, 567 U.S. 460 (2012), to Gates as an emerging adult. That claim must be litigated in postconviction proceedings. So we affirm. ¶3 Background ¶4 The Illinois Supreme Court recently set the framework for analyzing emerging-adult sentencing claims under the proportionate penalties clause. Spencer, 2025 IL 130015, ¶¶ 32-46. In doing so, it overruled part of our earlier ruling. Id. ¶ 40 (overruling People v. Gates, 2023 IL App (1st) 211422, ¶¶ 38-49). The court vacated our decision and ordered reconsideration in light of Spencer. People v. Gates, No. 130271 (Ill. Sept. 24, 2025) (supervisory order). We allowed supplemental briefing. ¶5 We recount the pertinent facts. ¶6 Trial ¶7 Sisters Tremia Gilmore and Ishonna Gilmore testified that they lived in a three-flat with siblings in territory claimed by the “Lowe Life” gang. On the evening of the shooting, they were with their cousin, a Lowe Life member, when Gates arrived and asked for him. ¶8 Terence Evans, who lived on the second floor, heard about seven shots, went to the rear, and saw Gates shoot the cousin twice and yell “F*** Lowe Life” before leaving. ¶9 Police investigators described the investigation. Detective Jeremy Morales testified that he spoke to the sisters and Evans the night of the shooting. All three identified Gates by his nickname, “Man Man.” With that information, Morales assembled a photo array. The next day, at the station, the sisters and Evans identified Gates as the shooter. -2- ¶ 10 Gates testified he knew the sisters, Evans, and the victim and had been friends until they affiliated with “Lowe Life.” He ended the friendship in 2016 because he belonged to a rival gang. He denied being in Englewood on the day of the shooting. ¶ 11 The j