Israel Ruiz v. J.b. Pritzker

24-1853Court of Appeals for the Seventh Circuit23 déc. 2025

Texte intégral

In the
United States Court of Appeals
For the Seventh Circuit
____________________
No. 24-1853
I SRAEL R UIZ ,
Plaintiff-Appellant,
v.
J.B. PRITZKER , et al.,
Defendants-Appellees.
____________________
Appeal from the United States District Court for the
Northern District of Illinois, Eastern Division.
No. 1:22-cv-07171 — John Robert Blakey, Judge.
____________________
A RGUED F EBRUARY 12, 2025 — DECIDED D ECEMBER 23, 2025
____________________
Before PRYOR , K OLAR , and M ALDONADO, Circuit Judges.
K OLAR , Circuit Judge. This case arises from Public Act 100-
1182, an amendment to the Illinois Unified Code of Correc-
tions that establishes a new parole system for young-adult of-
fenders. The Act provides, in relevant part, that certain indi-
viduals imprisoned for first-degree murder that they commit-
ted while under the age of 21 may seek parole review after
serving 20 or more years of their sentence. See 730 ILCS 5/5-

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2 No. 24-1853
4.5-115(b). But it only applies to individuals sentenced on or
after June 1, 2019. Id.
Plaintiff Israel Ruiz was convicted of a first-degree murder
that he committed when he was 18 years old, and in 2000 was
sentenced to 40 years in prison without the possibility of pa-
role. If the Act applied retroactively, Ruiz would be eligible
for a parole hearing. He asks us to hold that the Act’s nonret-
roactivity violates the Equal Protection Clause and the Eighth
Amendment’s prohibition of cruel and unusual punishment.
We disagree and affirm the district court’s judgment.
I. Background
Ruiz was born in May 1980. In 1998, he shot and killed a
man who was holding a child. An Illinois jury found him
guilty of first-degree murder and aggravated discharge of a
firearm. In 2000, Ruiz was sentenced to 40 years in prison
without the possibility of parole for the murder count and a
concurrent 15 years for the aggravated-discharge count.
In 2019, Illinois enacted new legislation expanding parole
eligibility for certain individuals sentenced as young adults.
See Pub. Act 100-1182, § 5, 2018 Ill. Laws 8923, 8938–42 (codi-
fied as amended at 730 ILCS 5/5-4.5-115). The legislation’s
supporters cited the Supreme Court’s decision in Miller v. Al-
abama, 567 U.S. 460 (2012), which held mandatory sentences
of life without parole for offenders under the age of 18 uncon-
stitutional, as a key inspiration for its passage. The Act states:
A person under 21 years of age at the time of the
commission of first degree murder who is sen-
tenced on or after June 1, 2019 (the effective date
of Public Act 100-1182) shall be eligible for pa-
role review by the Prisoner Review Board after

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No. 24-1853 3
serving 20 years or more of his or her sentence
or sentences, except for those subject to a term
of natural life imprisonment under Section 5-8-
1 of this Code or any person subject to sentenc-
ing under subsection (c) of Section 5-4.5-105 of
this Code, who shall be eligible for parole re-
view by the Prisoner Review Board after serving
40 years or more of his or her sentence or sen-
tences.
730 ILCS 5/5-4.5-115(b). The Act, by its terms, does not apply
to Ruiz because he was sentenced before June 1, 2019.
Ruiz filed a Section 1983 lawsuit against Illinois’s governor
and various state officials in their official capacities, alleging
that the Act’s prospective-only application violates his Four-
teenth and Eighth Amendment rights. He seeks declaratory
and injunctive relief for the Act to be applied to all young
adults sentenced for offenses they committed while under the
age of 21.
In his amended complaint, Ruiz alleges that the Illinois
General Assembly passed the Act based on its recognition that
young adults do not have “fully formed brains at eighteen or
at twenty-one,” expanding on the scientific underpinnings of
Miller and its progeny. He describes expert findings “that an
individual’s brain maturation is not ordinarily complete until
one reaches approximately 25 years of age[.]” In Ruiz’s view,
because scientific development applies no differently to of-
fenders who were sentenced before or after June 1, 2019, the
Act “creates two different parole systems for individuals con-
victed of similar or identical crimes based solely on the date
of their sentencing.” Thus, Ruiz alleges that Defendants

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4 No. 24-1853
violated the Constitution by “enacting, enforcing, and imple-
menting the Act [only] prospectively.”
Defendants moved to dismiss under Rule 12(b)(6) for
failure to state a claim. The district court granted the motion.1
It held that Ruiz could not state a Fourteenth Amendment
claim based on our rulings in United States v. Speed, 656 F.3d
714 (7th Cir. 2011), and United States v. Sanders, 909 F.3d 895
(7th Cir. 2018), which rejected equal protection claims based
on sentencing-date disparities after intervening changes in
criminal legislation. And on the Eighth Amendment claim,
the district court ruled that the Act’s prospective-only
application did not render Ruiz’s sentence cruel or unusual.
Ruiz now appeals.
II. Discussion
We review a district court's grant of a motion to dismiss de
novo. Word v. City of Chicago, 946 F.3d 391, 393 (7th Cir. 2020).
“To survive a motion to dismiss, a complaint must contain
sufficient factual matter, accepted as true, to state a claim to
relief that is plausible on its face.” Indiana Land Tr. #3082 v.
Hammond Redevelopment Comm'n, 107 F.4th 693, 698 (7th Cir.
2024) (citation omitted). We construe the complaint “in the
light most favorable to” Ruiz, accepting all well-pled facts as
true and drawing all inferences in his favor. Id. at 696.
1 The district court found that the State’s governor and attorney gen-
eral were entitled to sovereign immunity, but the director of the Depart-
ment of Corrections was not. The Prisoner Review Board chair did not
claim sovereign immunity.

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No. 24-1853 5
Ruiz contends that the district court erred in dismissing
his Fourteenth and Eighth Amendment claims. We discuss
each claim in turn.
A. Equal Protection
Ruiz argues that the Act’s nonretroactive grant of parole
eligibility violates the Fourteenth Amendment’s Equal Pro-
tection Clause by treating young adults differently based on
their sentencing date. “Equal protection of the laws means
that all persons similarly situated should be treated alike.”
United States v. Nagel, 559 F.3d 756, 760 (7th Cir. 2009). Ruiz’s
equal protection claim does not implicate a suspect classifica-
tion or fundamental right, so it is subject to rational-basis re-
view. Ostrowski v. Lake County, 33 F.4th 960, 966 (7th Cir. 2022).
This means that Ruiz must show there is no rational relation-
ship between the Act’s differential treatment and any conceiv-
ably legitimate government purpose. Srail v. Vill. of Lisle, 588
F.3d 940, 948 (7th Cir. 2009) (quoting Heller v. Doe, 509 U.S.
312, 320–21 (1993)). At the motion-to-dismiss stage, he must
do so by “alleg[ing] facts sufficient to overcome the presump-
tion of rationality that applies to government classifications.”
Flying J Inc. v. City of New Haven, 549 F.3d 538, 546 (7th Cir.
2008) (quoting Wroblewski v. City of Washburn, 965 F.2d 452,
460 (7th Cir. 1992)).
In Ruiz’s view, there is no defensibly rational basis for the
Act’s dividing line. He contends that individuals sentenced
before the Act’s effective date are no “more dangerous or less
capable of reformation” than those sentenced on or after this
date. Ultimately, he seeks to compel Defendants to extend the

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6 No. 24-1853
Act’s protections to individuals who would otherwise be cov-
ered by its text, regardless of their sentencing date.2
Defendants respond by identifying several rational bases
for the Act’s prospective-only application, including avoiding
financial and administrative burdens from additional parole
hearings and upholding finality for victims. The district court
held that our precedent forecloses Ruiz’s claim. We agree.
1. Speed and Sanders
We have repeatedly held that disparities between those
sentenced before and after a criminal statute’s effective date
do not violate equal protection. In United States v. Speed, we
held that the disparity in treatment arising from new sentenc-
ing legislation was “plainly rational.” 656 F.3d at 720. There,
the defendant asserted that his mandatory life sentence, im-
posed before the enactment of the Fair Sentencing Act of 2010,
resulted in an arbitrary disparity that violated his equal pro-
tection rights. Id. at 719–20. Had the Speed defendant been sen-
tenced a year later, he would have been sentenced to ten years
under the Fair Sentencing Act. Id. at 719. Even so, we ex-
plained that “discrepancies among persons who committed
similar crimes are inescapable whenever Congress raises or
lowers the penalties for an offense.” Id. at 720 (quoting United
States v. Goncalves, 642 F.3d 245, 253 (1st Cir. 2011)). When the
legislature chooses to amend or enact statutes that solely
2 Neither party has discussed whether the Act’s limitation to young-
adult offenders “sentenced on or after June 1, 2019” is properly severable
from the remainder of the Act. Bell v. Keating, 697 F.3d 445, 463 (7th Cir.
2012) (“Partial invalidation may not be possible ... if the legislature would
not have passed the law without the unconstitutional element[.]” (citation
omitted)). We need not address severability, as we conclude that Ruiz’s
claim fails on the merits.

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No. 24-1853 7
apply to future offenders, “[s]omeone … will always be left
behind to live with the earlier, harsher penalty[.]” Id.
Similarly, in United States v. Sanders, the defendant con-
tended that it was unconstitutional to apply a federal recidi-
vist enhancement statute to her sentence after a new state law
reclassified her prior felony drug conviction as a misde-
meanor. 909 F.3d at 900, 905. Like Ruiz, the Sanders defendant
contended that this application “create[d] two classes”—
those convicted before the law was passed and those after—
without any legitimate basis for doing so. Id. at 905. We re-
jected that argument, again holding that such distinctions are
rational and that discrepancies are “inescapable” when legis-
latures “raise[] or lower[] the penalties for an offense.”3 Id.
(quoting Speed, 656 F.3d at 720).
Ruiz’s arguments do not meaningfully differ from those
made (and rejected) in Speed and Sanders. He initially attempts
to distinguish those cases on procedural grounds, noting that
both arose at criminal sentencings with the benefit of a more
3 The Illinois Supreme Court has followed similar logic in finding that
prospective-only applications of criminal statutes do not violate equal
protection. People v. Richardson, 2015 IL 118255, ¶ 10 (reaffirming that “nei-
ther the fourteenth amendment nor the Illinois Constitution prevents stat-
utes and statutory changes from having a beginning”); People v. Grant, 71
Ill. 2d 551, 562 (1978) (upholding a prospective-only sentencing law). We
note as well that several districts of the Illinois Appellate Court have ap-
plied Richardson in foreclosing equal protection challenges to the Act, in
cases nearly identical to Ruiz’s. See People v. Profit, 2023 IL App (1st)
210881, ¶¶ 34–37; People v. Barry, 2023 IL App (2d) 220324, ¶¶ 19–24; People
v. Wells, 2023 IL App (3d) 210292, ¶¶ 29–33, 44; People v. Lowder, 2023 IL
App (4th) 220315-U, ¶¶ 42–46. While we are certainly not bound by the
Illinois courts’ interpretation of the federal Constitution, we acknowledge
these decisions under principles of comity.

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8 No. 24-1853
developed fact record. But we have held that the rational-
basis test “can often be applied in advance of discovery.”
Flying J, 549 F.3d at 546 (quoting Lauth v. McCollum, 424 F.3d
631, 634 (7th Cir. 2005)). The critical question, rather, is
whether the sentencing issues presented in Speed and Sanders
are meaningfully distinct from the issue of parole eligibility
presented in this case. Despite Ruiz’s best arguments to the
contrary, they are not.
2. Financial and Administrative Burdens
Ruiz first contests whether the cost and burden of addi-
tional parole hearings present a rational basis for applying the
Act only prospectively. He argues that it costs Illinois $38,000
to house an inmate for one year, which will amount to
$532,000 for the remaining 14 years of his own sentence—
dwarfing any potential savings from denying him and others
like him a parole hearing. Ruiz also contends that, unlike the
potential resentencings at issue in Speed and Sanders, parole
hearings require no judicial resources and do not meaning-
fully tax the State’s resources. For support, Ruiz cites the Su-
preme Court’s observation in Montgomery v. Louisiana that
“[e]xtending parole eligibility to juvenile offenders does not
impose an onerous burden on the States, nor does it disturb
the finality of state convictions.” 577 U.S. 190, 212 (2016).
Ruiz failed to include this latter allegation in his amended
complaint. But it highlights another distinction between his
case and the Supreme Court’s precedent. In Montgomery, the
Supreme Court held that Miller’s constitutional ban on life
without parole for offenders who were under 18 at the time
of their crimes should be applied retroactively. Id. But Miller
and Montgomery addressed distinct legal issues under the
Eighth Amendment, not the Equal Protection Clause. And

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No. 24-1853 9
their constitutional protections have not been extended to
young-adult offenders like Ruiz who committed their crimes
at or over the age of 18. As a result, neither case prohibits Illi-
nois from making conceivably rational distinctions based on
its interests.
Even if we could entertain the kind of cost-benefit analysis
that Ruiz asks us to undertake on rational-basis review, his
argument is unavailing. See FCC v. Beach Commc’ns, Inc., 508
U.S. 307, 315 (1993) (legislative choices are “not subject to
courtroom fact-finding” and need not be “[]supported by ev-
idence or empirical data”). Parole hearings—whether or not
they are “onerous”—are not costless either, and Ruiz’s argu-
ment presupposes that they will routinely lead to release. See
Montgomery, 577 U.S. at 212 (“Those prisoners who have
shown an inability to reform will continue to serve life sen-
tences.”). The State was within its rights to weigh the compar-
ative cost of retroactive parole hearings and rationally con-
clude that they were not justified. See Pryor v. Brennan, 914
F.2d 921, 925 (7th Cir. 1990) (avoiding administrative burden
is a legitimate government interest).
3. Finality for Victims
Ruiz also challenges the rationality of the State’s asserted
interest in providing victims with finality by applying the Act
on a prospective-only basis. He points out that the Act con-
tains specific procedures allowing victims or their families to
participate in the parole process. See 730 ILCS 5/5-4.5-115(g)
(requiring Prisoner Review Board to provide twelve months’
advance written notice of parole hearings to victim or their
family and offer them the opportunity to make an oral state-
ment and submit information).

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10 No. 24-1853
This language notwithstanding, the Act’s legislative his-
tory makes clear that ensuring finality for victims was a cen-
tral consideration in limiting its retroactive application. Both
the Illinois Senate and House of Representatives bill sponsors
confirmed to their respective chambers that the Act would not
affect any person currently serving time in order to respect
victims’ concerns. See 100th Ill. Gen. Assem., Senate Proceed-
ings, May 31, 2017, at 36 (statement of Sen. Harmon); 100th Ill.
Gen. Assem., House Proceedings, Nov. 28, 2018, at 52–53, 61–
62 (statement of Rep. Currie).
The legitimacy of ensuring finality for victims is well-
established. Calderon v. Thompson, 523 U.S. 538, 539 (1998)
(“Only with an assurance of real finality can the State execute
its moral judgment and can victims of crime move forward
knowing the moral judgment will be carried out. Unsettling
these expectations inflicts a profound injury to the powerful
and legitimate interest in punishing the guilty.” (citation
omitted)); see also Wells, 2023 IL App (3d) 210292, ¶ 43 (“[T]he
State has a weighty interest in the finality of … sentences.”
(citation omitted)). Victim finality alone is sufficient for us to
find that the Act is rationally related to the State’s legitimate
interest.
Because Ruiz has failed to allege facts sufficient to over-
come the strong presumption of rationality to which the Act
is entitled, we affirm the district court’s dismissal of his equal
protection claim.
B. Eighth Amendment
Ruiz also challenges the Act’s prospective-only applica-
tion under the Eighth Amendment. He alleges that excluding
him from relief for which he would be eligible if he were

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No. 24-1853 11
sentenced after June 1, 2019 violates the Constitution’s ban on
cruel and unusual punishment.
Under “bedrock Eighth Amendment principles,” we must
evaluate whether punishments are “cruel and unusual” in
light of “the evolving standards of decency that mark the pro-
gress of a maturing society.” Walton v. Nehls, 135 F.4th 1070,
1072, 1074 (7th Cir. 2025) (quoting Hudson v. McMillian, 503
U.S. 1, 8 (1992)). Ruiz’s Eighth Amendment claim turns on the
“evolving standards” underlying the Supreme Court’s deci-
sions in Miller and Montgomery. He argues, in essence, that the
Act’s nonretroactive application cannot be squared with the
scientific and societal reckoning on the “diminished culpabil-
ity” of young offenders embodied in that case line. Montgom-
ery, 577 U.S. at 195 (quoting Miller, 567 U.S. at 479).
As we have already noted, Ruiz indisputably falls outside
the ambit of Miller and its progeny. Miller applies to “those
under the age of 18 at the time of their crimes” who received
a sentence of mandatory life without parole. 567 U.S. at 465.
Ruiz was 18 years old when he was charged, so he does not
meet Miller’s criteria under currently applicable caselaw. See
In re Manning, 24 F.4th 1107, 1109 (6th Cir. 2022) (Miller’s
“‘new rule’ unambiguously applies to only those who were
under 18 at the time of their offense”).4
4 Ruiz also contends that his 40-year sentence should be considered de
facto life without parole. But see Sanders v. Eckstein, 981 F.3d 637, 642–43
(7th Cir. 2020) (juvenile offender first eligible for release at age 51 did not
receive de facto life sentence). Ruiz argues that Sanders and like cases did
not consider “recent studies” on the life expectancy of young-adult of-
fenders in prison, citing an allegation in his complaint that incarcerated
youths have an average life expectancy of only 50.6 years. But whether
this is true is a question for another case: Ruiz is still over Miller’s age cut-

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12 No. 24-1853
Still, Ruiz argues that the Act’s prospective-only applica-
tion renders his sentence cruel and unusual because it is
purely “arbitrary.” In support, he invokes Justice Douglas’s
concurrence in Furman v. Georgia to argue that “legislatures
[must] write penal laws that are evenhanded, nonselective,
and nonarbitrary” under the Eighth (as well as the Four-
teenth) Amendments. 408 U.S. 238, 256 (1972) (Douglas, J.,
concurring). To the extent that the Eighth Amendment incor-
porates equal protection principles, they are not violated here
for the same reasons discussed above: unlike the Black de-
fendants in Furman, Ruiz does not contend that the Act bears
on any protected status, and the State has advanced ample
support that its law is not irrational (let alone arbitrary).
Ruiz also insists that—though he is not entitled to direct
relief under Miller and Montgomery—their teachings still call
into question the “penological purposes” served by keeping
him imprisoned without the possibility of parole. Atkins v.
Virginia, 536 U.S. 304, 317 (2002). But his assertion is mis-
placed. Atkins was a death-penalty case in which the Supreme
Court found that executing intellectually disabled prisoners
violated the Eighth Amendment based in part on a “national
consensus” among state legislatures that such punishment
was inappropriate. Id. at 314–17; see also Walton, 135 F.4th at
1075 (“[T]he clearest and most reliable objective evidence of
contemporary values is the legislation enacted by the coun-
try’s legislatures.” (citation omitted)).
off, and even if we did conclude that his sentence is de facto life without
parole, this would not answer whether the Act—the subject of Ruiz’s con-
stitutional challenge—violates the Eighth Amendment.

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No. 24-1853 13
We cannot definitively conclude that such a “national con-
sensus” exists today on extending Miller and Montgomery’s
protections to young-adult offenders like Ruiz, though we
acknowledge that this is a rapidly evolving area of law in the
states.5 While Illinois’s passage of Public Act 100-1182 is of a
piece with this trend, the General Assembly specifically de-
clined to extend the Act’s protections to offenders like Ruiz
retroactively. We will not supersede that legislature’s author-
ity to make these policy judgments in the first instance. See
Jones v. Mississippi, 593 U.S. 98, 119–20 (2021).
5 In recent years, at least three state supreme courts have found man-
datory life sentences without parole for 18- to 20-year-old offenders un-
constitutional under their respective state constitutions. See Matter of
Monschke, 482 P.3d 276, 280 (Wash. 2021) (en banc); Commonwealth v.
Mattis, 224 N.E.3d 410, 415 (Mass. 2024); People v. Taylor, No. 166428, 2025
WL 1085247, at *6 (Mich. Apr. 10, 2025). Many state legislatures have also
expanded protections for emerging adult offenders in light of neuroscien-
tific research suggesting that the transition into adulthood is gradual and
highly individualized. See, e.g., Act 152, 2025 Haw. Sess. Laws 350–51 (pro-
hibiting life imprisonment without parole for offenders under the age of
21); Conn. Gen. Stat. § 54-125a (broadening parole eligibility for certain
offenders under the age of 21); Colo. Rev. Stat. § 17-22.5-403.7 (same); Cal.
Penal Code § 3051(a)(1) (same for certain offenders under the age of 26);
La. Stat. Ann. § 15:574.4(B)(2)(a) (same for certain offenders under the age
of 25); Vt. Stat. Ann. tit. 33, § 5201 (extending juvenile courts’ jurisdiction
for qualifying crimes to offenders aged 19); H.B. 853, 2025 Md. Laws ch.
96 (permitting certain offenders convicted between ages 18 and 25 to move
for sentence reduction); D.C. Code § 24-403.03 (same). Given the implica-
tions of these states’ changes for “evolving standards of decency” under
the federal Constitution, Ruiz is not unreasonable to suggest that “at some
point in the not-too-distant future, the [Supreme] Court might revise the
Miller line of cases,” raising the “Eighth Amendment age-line to 22[.]” Ruiz
v. United States, 990 F.3d 1025, 1040 (7th Cir. 2021) (Wood, J., dissenting).
But we will not claim the prerogative to do so ourselves here.

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14 No. 24-1853
We reiterate that “[a legislature’s] amendment to the stat-
utory penalties does not transform the preexisting penalty
scheme into a cruel and unusual one.” Speed, 656 F.3d at 720
(holding that Fair Sentencing Act’s passage did not render de-
fendant’s mandatory life sentence cruel and unusual); see also
United States v. Blewett, 746 F.3d 647, 660 (6th Cir. 2013) (“[T]he
Eighth Amendment is not a ratchet that makes a harsher sys-
tem of penalties unconstitutional the moment a more lenient
one is (prospectively) adopted, a theory that would have the
perverse effect of discouraging lawmakers from ever lowering
criminal sentences.”). Ruiz asks us to broaden the Illinois leg-
islature’s selective extension of Miller’s protections beyond
the constitutional baseline set by the Supreme Court; this we
cannot do. Because there is no pathway for Ruiz to state an
Eighth Amendment claim under current precedent, we affirm
the district court’s dismissal.
III. Conclusion
For the reasons discussed herein, we AFFIRM.

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