People v. Ligon

This case presents question as to whether defendant’s sentence of mandatory natural life under Habitual Criminal Act on charge of aggravated vehicular hijacking while armed with dangerous weapon was void as violation of proportionate penalties clause of Ill. Constitution. Appellate Court agreed with defendant that his sentence was void, and that he should have been sentenced for Class 1 offense since: (1) his Class X offense of aggravated vehicular hijacking had identical elements of proof required for conviction in Class 1 offense of armed violence predicated on vehicular hijacking with dangerous weapon; and (2) defendant should not have been sentenced to mandatory natural life imprisonment under habitual offender statute where instant conviction was actually either Class 1 or Class 2 offense.