People v. Baker, 173 N.E.3d 244

On Sept. 8, 2014, Jermaine Baker was arrested and made incriminating, unrecorded statements during interrogation about a home invasion and shooting.
Recording equipment was available in the interview room; detectives testified recordings were not mandatory and one detective said counsel ended the interview before he could ask to record a subsequent interview.
Public Act 98-547 (eff. Jan. 1, 2014) added 725 ILCS 5/103-2.1(b-5), creating a presumption that unrecorded custodial statements about listed violent felonies are inadmissible unless electronically recorded; the Act’s expansion to additional offenses was phased in over three years.
Home invasion was not covered by the new subsection until June 1, 2015; Baker’s interrogation occurred before that date (Sept. 2014).
Baker moved to suppress his statements (arguing among other things noncompliance with the recording requirement for attempted first-degree murder), was convicted at trial, sentenced to 48 years, and appealed raising a facial equal protection challenge to the statute’s staggered effective dates.
The appellate court rejected the facial challenge, finding a rational basis for the phased rollout grounded in legislative concerns about law‑enforcement capacity and equipment costs; it affirmed the denial of suppression.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Baker)	Held
Whether the staggered effective dates for expanding 725 ILCS 5/103-2.1(b-5) (phased inclusion of certain violent felonies) violate equal protection on their face	The statute is presumptively constitutional; classifications that do not target a suspect class or fundamental right are reviewed under a deferential rational‑basis test and are justified by legislative concerns about implementation; facial challenges can be raised on appeal	No rational basis for staggered effective dates; rollout not justified by costs or capacity because equipment costs were budgeted and some departments already had equipment; staggered dates treat similarly situated defendants differently without justification	The appellate court held the statute is facially constitutional: the phased implementation is rationally related to legitimate legislative goals (allowing law‑enforcement agencies time and resources to comply), so Baker’s equal protection challenge fails

People v. Thompson, 2015 IL 118151 (Ill. 2015) (facial constitutional challenge may be raised at any time)
People v. One 1998 GMC, 2011 IL 110236 (Ill. 2011) (statute presumed constitutional; facial challenges difficult to prevail on)
People v. Johnson, 225 Ill. 2d 573 (Ill. 2007) (courts construe statutes in a manner that upholds constitutionality if reasonable)
People v. Boeckmann, 238 Ill. 2d 1 (Ill. 2010) (resolve doubts in favor of validity when construing statutes)
People v. Dean, 363 Ill. App. 3d 454 (Ill. App. Ct. 2006) (outline of rational‑basis review for non‑suspect classifications)
Russell v. Dep’t of Natural Resources, 183 Ill. 2d 434 (Ill. 1998) (classification upheld if any conceivable factual basis justifies it)