People v. Gay 

Defendant was convicted of aggravated battery for assaulting DOC corrections officer, and sentenced to extended term of six years, to run consecutively to sentences received in other cases. At time of his postconviction petition, Defendant alleged cruel and unusual punishment, as his 16 aggravated-battery convictions resulting in 97 years of consecutive sentences were de facto life without parole and he is less culpable given his mental illness. No national consensus has developed against sentencing mentally ill persons as severely as others. Criminal statute is sufficient to provide notice required for due process, and DOC's citation of Defendant for conduct did not affect State's power to charge him. (KNECHT and McCULLOUGH, concurring.)