People v. Duffie

Defendant was convicted of escape, 730 ILSC 5/5-8A-4.1(a), based on evidence that he violated the terms of his pretrial release in an underlying prosecution by removing an electronic monitoring device from his ankle. Defendant argued on appeal that his conviction must be reversed because he was not given notice that a failure to comply could lead to a prosecution for escape and that the court failed to conduct proper proceedings under Batson v. Kentucky. The appellate court rejected defendant’s notice argument, but remanded for compliance with Batson. (JORGENSEN and SCHOSTOK, concurring)