People v. Bingham

Defendant was convicted, after bench trial in 2014, of felony theft. Defendant had a prior conviction for attempted criminal sexual assault in 1983, but he was not required to register as a sex offender at the time as conviction was prior to enactment of Sex Offender Registration Act. Under Act as amended in 2011, 2014 felony theft conviction triggered required that he register as a sex offender becuase of 1983 conviction. Defendant cannot raise his as-applied constitutional challenge for the first time in the reviewing court in a collateral proceeding without benefit of a factual record. (KARMEIER, KILBRIDE, GARMAN, BURKE, THEIS, and NEVILLE, concurring.)