Illinois Appellate Court
Criminal Court
Orders of Protection
Defendant was convicted, after jury trial, of violating order of protection. Conviction was Class 4 felony based on his prior unlawful-restraint conviction, which was not an element of offense per Section 111-3(c) of Criminal Procedure Code, and thus he was properly sentenced to extended term. State was not required to prove fact of Defendant's prior conviction for unlawful restraint to jury. (TURNER and STEIGMANN, concurring.)