People v. Casas

Illinois Appellate Court
Criminal Court
Limitations
Citation
Case Number: 
2018 IL App (2d) 150456-B
Decision Date: 
Friday, April 20, 2018
District: 
2d Dist.
Division/County: 
Du Page Co.
Holding: 
Reversed and remanded.
Justice: 
HUTCHINSON

State's reference to Defendant's usingĀ of a false identification to evade prosecution, in the information, qualifies as an exception to the limitations period applicable when a criminal defendant is not usually and publicly resident within Illinois, under section 3-7(a) of the Criminal Code of 2012. Thus, informationĀ set forth circumstances that ultimately, if proven, would toll limitations period under section 3-7(a), namely, that Defendant was living under a false identity from July 1998 to April 2014, which was clear enough to provide required notice to Defendant that State would rely on those circumstances to toll limitations period.(HUDSON and SPENCE, concurring.)