People v. Le Mirage, Inc. 

(Court opinion corrected 11/19/13.) Circuit court ordered Respondents to vacated second floor of nightclub due to building code violations, but Respondents continued to operate club, and 21 people were crushed to death in panic upon police efforts to subdue a fight. Court convicted Respondents of indirect criminal contempt and sentenced them to two years imprisonment. Court improperly relied on nightclub tragedy in aggravation, and appellate court remanded for new sentencing hearing. During sentencing a trial court may not consider in aggravation deaths that were factually but not proximately caused by Respondents' indirect criminal contempt. (HOWSE and LAVIN, concurring.)