People ex rel. Alvarez v. $59,914 United States Currency

Summary

The Illinois Supreme Court affirmed the denial of Salaam's petition challenging a currency-forfeiture judgment entered after he allegedly received no statutory notice. The court held that the circuit court had subject-matter jurisdiction and in rem jurisdiction over the currency, so any notice error made the judgment voidable rather than void. Because Salaam filed his section 2-1401 petition more than two years after the forfeiture judgment, the petition was untimely.