People v. Sroga

Summary

The court held that the offense under section 4-104(a)(4) requires knowledge that the displayed license plate is unauthorized for the vehicle, while the parallel offense under section 3-703 imposes absolute liability. Because the offenses therefore have different mental-state elements, the harsher penalty for the section 4-104(a)(4) offense does not violate the Illinois proportionate penalties clause. The court affirmed dismissal of the section 2-1401 petition and did not reach the remedy question.