Illinois Supreme Court
People v. Stewart
October 20, 2022465 Ill. Dec. 547
Summary
The court held that Stewart's 2013 residential-burglary conviction, committed when he was 17, was not a qualifying predicate offense for mandatory Class X sentencing under the version of the statute then in effect. The court treated a later statutory amendment requiring the first qualifying offense to have been committed at age 21 or older as a clarification of the prior statute, resolving the statute's silence and conflicting appellate interpretations. Because Stewart was statutorily ineligible for Class X sentencing, the court affirmed the appellate court's vacation of his sentence and remand for resentencing as a Class 2 offender.