People v. Vlahon

Illinois Appellate Court
Criminal Court
Sentencing
Citation
Case Number: 
2012 IL App (4th) 110229
Decision Date: 
Thursday, October 11, 2012
District: 
4th Dist.
Division/County: 
Sangamon Co.
Holding: 
Affirmed as modified; remanded with directions.
Justice: 
KNECHT
Court improperly attached term of four years MSR to Defendant's aggravated domestic battery conviction, in violation of ex post facto doctrine, as two-year MSR term was provided for under statute in effect at time Defendant committed the offense. Four-year MSR term is not simply a condition of Defendant's sentence, but is a two-year increase in length of time Defendant is subject to custody of DOC. (STEIGMANN and COOK, concurring.)