People v. Fields

Defendant was convicted, after jury trial, of armed robbery and being an armed habitual criminal (AHC). As a result of Defendant's failure to vacate his prior AUUW (aggravated unlawful use of a weapon) conviction prior to the time he possessed a firearm, his prior AUUW conviction could serve as the predicate offense for his AHC conviction. State was required only to prove "status" of Defendant's prior convictions to establish AHC and not their reliability. The 2007 statutory amendment which revived sentencing enhancement is constitutional. Thus, Defendant's 15-year enhancement for use of a firearm was not unconstitutional.(NEVILLE and MASON, concurring.)