After a jury convicted Defendant of driving while his license was revoked, the court sentenced him to 18 months imprisonment for a Class 4 felony. Defendant appealed, arguing that his conviction should be reduced to a Class A misdemeanor because the State did not prove the reason for his license revocation beyond a reasonable doubt. Court properly found that the State is not required to prove the reason for the original revocation beyond a reasonable doubt. Defendant also argued that the State failed to adequately establish that his license was revoked for DUI at sentencing. It was reasonable for the trial court to infer that Defendant's license was revoked for a DUI at the time of the offense, because Defendant’s presentence investigation report reflected Defendant's prior DUI convictions and did not indicate that his license was reinstated. (KNECHT, concurring; APPLETON, dissenting.)
Illinois Appellate Court
Criminal Court
Driving While Revoked