People v .Castillo

Defendant was convicted of two counts of aggravated battery. On appeal, defendant argued that the State failed to prove him guilty of aggravated battery because a cellblock in a maximum-security prison that is not accessible to the public is not “public property” for the purposes of the aggravated battery statute and the State failed to prove ownership of the property at issue. The supreme court affirmed the defendant’s conviction and sentence, finding that the prison was public property for the purposes of the aggravated battery statute and that it was proper for the court to take judicial notice of an element of the offense where the fact was readily verifiable “from sources of indisputable accuracy” and that there was no question regarding the ownership of the prison where the offense occurred. (THEIS, ANNE M. BURKE, NEVILLE, OVERSTREET, and CARTER, concurring. HOLDER WHITE took no part in the decision.)