Illinois Appellate Court
Civil Court
Proof Beyond a Reasonable Doubt
(Modified upon denial of rehearing 11/1/17.) Defendant was convicted, after stipulated bench trial, of escape for her failure to report to county jail immediately after her discharge from a halfway house as ordered as a bond condition. As State could not establish that Defendant was in custody, a requirement inherent in the offense of escape, it could not prove she was guilty of escape beyond a reasonable doubt. (HOLDRIDGE and McDADE, concurring.)