People v. Castillo

This case presents question as to whether government proved defendant guilty of aggravated battery of inmate “on public property” beyond reasonable doubt, where said battery occurred in cell block in maximum security prison. While defendant argued that said cell block was not on “public property” so as to preclude him from being found guilty of charged offense, Appellate court, in affirming defendant’s conviction, found that it need not address said issue because, as charged in instant indictment, government needed to show only that defendant knew that battery occurred at Pontiac prison, which is public property, and not at any specific location within prison. It also observed that: (1) ordinary meaning of “public property” was simply property owned by government; and (2) ownership of prison could be established through judicial notice.