Israel Ruiz v. J.B. Pritzker

In the

United States Court of Appeals

For the Seventh Circuit

____________________

No. 24-1853

ISRAEL RUIZ,

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.

____________________

ARGUED FEBRUARY 12, 2025 — DECIDED DECEMBER 23, 2025

____________________

Before PRYOR, KOLAR, and MALDONADO, Circuit Judges.

KOLAR, 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-

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

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

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.

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

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.

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.

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

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).

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

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-

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.

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.

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.