Yates v. People

Summary

The court held that proportionality review of habitual-criminal sentences must examine each triggering offense together with the predicate offenses supporting it, and must account for relevant later legislative amendments even when those amendments are nonretroactive. It further held that narcotic offenses generally, and possession and possession with intent specifically, are not categorically per se grave or serious; their gravity must ordinarily be determined from the facts and circumstances. The court reversed and remanded for individualized proportionality review of each sentence.