People v. Chenoweth, 2015 IL 116898

Victim Ella Stathakis (born 1928) signed a statutory property power of attorney in March 2003, granting broad authority to her stepdaughter, Barbara Chenoweth.
In March 2005 Chenoweth sold Ella’s house and deposited proceeds into Ella’s Bank of America checking account but retained substantial cash from several deposits.
In September–October 2008 an elder-services agency acquired a new property power of attorney for Ella and referred suspected missing funds to Detective Thomas Liesen; he interviewed Ella on October 15 and again on December 5, 2008.
Detective Liesen subpoenaed Ella’s bank records (received December 2, 2008), investigated further, and delivered his police report to the Adams County State’s Attorney on January 22, 2009.
The State indicted Chenoweth on December 21, 2009 (charges alleging offenses between Dec. 2004 and July 2005); the circuit court convicted her and sentenced probation and restitution; the appellate court vacated the conviction as time-barred under the extended statute of limitations.
The Illinois Supreme Court reviewed whether the one-year extension in 720 ILCS 5/3-6(a)(2) was triggered by the victim’s December 5, 2008 awareness or by the prosecutor’s January 22, 2009 receipt of the police file.

Issue	Plaintiff's Argument (People)	Defendant's Argument (Chenoweth)	Held
Whether the one-year extension in 720 ILCS 5/3-6(a)(2) began when the aggrieved person "discovered the offense" (Dec. 5, 2008) or when the proper prosecuting officer became aware (Jan. 22, 2009)	Section 3-6(a)(2) was triggered when the prosecutor received the police file on Jan. 22, 2009, so indictment (Dec. 21, 2009) was timely	Ella discovered the offense on Dec. 5, 2008 (she knew checks were written without her authorization), so the one-year period expired Dec. 5, 2009 and indictment was untimely	The Court held the aggrieved person had not "discovered the offense" on Dec. 5, 2008 because suspicion or awareness of losses is not the same as knowledge that a penal statute was violated; the one-year extension began Jan. 22, 2009 when the prosecutor received the file, so indictment was timely.
Whether remand is required for unaddressed claim that defendant is entitled to statutory credit for pretrial custody	N/A (State conceded entitlement)	Chenoweth argued she was entitled to statutory credit	The Court remanded to the appellate court to address the credit issue.

People v. Gray, 396 Ill. App. 3d 216 (construing which charging date controls for limitations analysis)
People v. Cray, 209 Ill. App. 3d 60 (discussing indictment date rules)
People v. McGreal, 4 Ill. App. 3d 312 (interpreting "discovery" language in section 3-6)
People v. Campa, 217 Ill. 2d 243 (noting courts avoid deciding nonessential issues)
People v. Zimmerman, 239 Ill. 2d 491 (statutory-construction principles applied to Criminal Code provisions)