People v. Barajas, 115 N.E.3d 459

In 2002 defendant Overath Barajas pled/guilty or was found guilty in three traffic cases and was ordered to pay fines: $650 (02-TR-10880), $1,000 (02-TR-19427), and $501 (02-TR-19429).
Two October 2002 judgments were entered ex parte after defendant failed to appear; fines remained largely unpaid for years.
In April 2016 Barajas, then incarcerated and earning $10/month, moved under 730 ILCS 5/5-9-2 to revoke the unpaid fines, submitting an affidavit of finances and citing inability to pay and post-release hardships.
The trial court revoked $32 of one file’s balance (02-TR-10880) but denied revocation for the other two files, reasoning Barajas had not shown good cause because he had paid very little over the prior 14 years.
Barajas appealed, arguing the court applied the wrong legal standard by considering prior payment history instead of focusing solely on inability to pay or hardship.

Issue	Plaintiff's Argument (People)	Defendant's Argument (Barajas)	Held
Whether the trial court applied the correct "good cause" standard under 730 ILCS 5/5-9-2 when deciding a motion to revoke fines	People defended the court’s consideration of prior payments/diligence in denying revocation for two files	Barajas argued "good cause" means inability to pay or hardship; prior payment history is not part of the statutory standard	Appellate court held the trial court applied the incorrect standard by considering prior diligence; vacated the denial and remanded for the court to consider only inability to pay or hardship

In re B.L.S., 202 Ill. 2d 510 (Illinois 2002) (council commentary is persuasive authority on statutory meaning)
People v. Ross, 168 Ill. 2d 347 (Illinois 1995) (council commentary may guide statutory interpretation)
People v. Ruff, 115 Ill. App. 3d 691 (Ill. App. Ct. 1983) (post-sentence safeguards, like fine-revocation procedure, protect those unable to pay)