People v. Reese

Defendant was convicted, after jury trial, of aggravated vehicular hijacking, vehicular invasion, attempted armed robbery, and escape, and sentenced to concurrent extended-term sentences of 50, 30, 30, and 14 years, to be served consecutively to natural life sentence he was serving on prior murder conviction. Court violated Defendant's right to due process by failing to undertake a Boose analysis and state reasons for shackling on the record before requiring him to remain shackled at trial, but error was limited and harmless. Where Defendant testified that he tried to escape out of necessity, to expose inhumane conditions in jail, State was entitled to present evidence of jury's finding in prior conviction to establish Defendant faced potential life sentence and sought to escape for that reason. Court substantially complied with Rule 401(a), so his waiver of counsel was valid. As convictions did not arise from unrelated courses of conduct, court could only impose extended term sentence on offenses within most serious class of felony. State failed to prove taking element of vehicular hijacking, as no evidence that he took possession or custody of bus he boarded upon escape from hospital prior to sentencing for murder conviction.(GORDON, concurring; PALMER, specially concurring.)