Background
After a bench trial in Cook County, Domonick Coleman was convicted of two counts of predatory criminal sexual assault and four counts of criminal sexual assault. The convictions arose from Coleman’s repeated sexual abuse of S.D., his fiancée’s daughter, who lived with Coleman and her mother from ages 11 to 17 and regarded Coleman as a parent.
The circuit court imposed 10 years on each count, to run consecutively, for an aggregate 60-year prison term. Coleman did not challenge his convictions. He argued on appeal that the sentence was excessive because it would likely imprison him into his eighties and insufficiently accounted for his lack of criminal history, employment, family ties, health, age, and rehabilitative potential.
The Court’s Holding
The appellate court affirmed. Each 10-year sentence was within the applicable statutory range, and the mandatory consecutive terms produced an aggregate range of 28 to 180 years. The 60-year total was therefore not an abuse of discretion or manifestly disproportionate to the offenses.
The court held that the sentencing record showed the circuit court considered the presentence report and expressly addressed Coleman’s age, health, family relationships, education, and rehabilitative potential. It was entitled to give greater weight to the seriousness of Coleman’s repeated sexual assaults of a child in his household who viewed him as a father figure.
The appellate court also concluded that the trial court’s imprecise discussion of extended-term sentencing did not affect the result. The applicable predatory-sexual-assault statute authorized a 6-to-60-year sentence, and the 10-year terms imposed were at the low end of the available range.
Key Takeaways
- A within-range sentence will not be disturbed absent an abuse of discretion.
- A sentencing court may prioritize the seriousness of repeated sexual offenses over mitigation and rehabilitation.
- The fact that consecutive sentences will extend into a defendant’s old age does not alone make the sentence excessive.
Why It Matters
The decision underscores the deference Illinois reviewing courts give to trial judges’ sentencing determinations when the record reflects consideration of mitigation. It also illustrates that mandatory consecutive sentencing can sustain a lengthy aggregate term even where each individual sentence is comparatively low.