Illinois Appellate Court
Criminal Court
Sentencing
Office of State Appellate Defendant is allowed to withdraw as counsel on appeal as no meritorious issues can be raised. Defendant was properly admonished that any prison term would be followed by three years MSR before his guilty plea. Defendant was not deprived of the benefit of the bargain, as he and the State could not have agreed to waive MSR. MSR, which is an included part of a sentence rather than in addition to a sentence, is not a form of imprisonment or an unlawful constraint upon liberty. (KNECHT, concurring; TURNER, specially concurring.)