People v. Lake

Defendant was convicted, after jury trial, of first-degree murder of 14-year-old boy, and sentenced to 45 years. Court did not err in sua sponte dismissal of Defendant's pro se Section 2-1401 petition for relief from judgment. State had actual notice of Defendant's petition when an Assistant State's Attorney was present in open court when petition was docketed. State is not required to respond to petition for relief from judgment. Petition was without merit, as enforcement of mandatory MSR term is not an increase in sentencing, as MSR term attaches automatically as though written into Defendant's sentence. (PALMER and GORDON, concurring.)