People v. Casas

This case presents question as to whether applicable 3-year limitations period is tolled on offense of violation of bail bond until offender is returned to custody, where defendant was apprehended 18 years after he had failed to appear in court on Class X felony charge. Trial court granted defendant’s motion to dismiss, after finding that violation of bail bond charge is not continuing offense. Appellate Court, though, held that offense of violation of bail bond was continuing offense because it constituted single course of action that continued beyond initial commission of offense. Appellate Court, though, acknowledged that its decision was in conflict with Grogan, 197 Ill.App.3d 18.