Illinois Appellate Court
Criminal Court
Armed Habitual Criminal
Defendant was found guilty of being an armed habitual criminal and was sentenced to six years in prison. Defendant argued on appeal that the trial court erred in denying his motion to dismiss because police lacked reasonable suspicion to frisk and search defendant for weapons and that the State failed to prove him guilty beyond a reasonable doubt. The appellate court affirmed, finding that police had probable cause for the search and that changes to the criminal code that would have resulted in one of defendant’s predicate offenses being a juvenile offense were not retroactive. (FITZGERALD SMITH and COGHLAN, concurring)