People v. Johnson

Summary

The Illinois Supreme Court held that the circuit court plainly erred by treating the defendant's relationship with the victim as a statutory aggravating factor, but that the forfeited error was not reviewable under the second prong of the plain-error rule. Because the error was not structural and was subject to harmless-error analysis, it could be reviewed only under the first prong, which the defendant did not invoke. The court affirmed the appellate court's judgment affirming the sentence.