People v. Sroga

Summary

The Illinois Supreme Court affirmed dismissal of Sroga's collateral petition, holding that the two Vehicle Code provisions addressing display of an unauthorized license plate do not have identical elements because one requires knowledge and the other imposes absolute liability. Because the offenses have different mental-state requirements, the harsher penalty for the knowledge-based offense does not violate the Illinois proportionate penalties clause. The court did not reach the proposed remedy for a constitutional violation because it found no violation.