People v. Gray, 2021 IL App (1st) 191086

In June 2016 police found Gray in a car and recovered a gun from the glove compartment; he was charged under the armed habitual criminal statute (720 ILCS 5/24-1.7).
Gray and the prosecutor negotiated plea offers; the trial court ultimately refused to accept a guilty plea after questioning voluntariness.
At trial the parties stipulated Gray had two prior felony convictions: unlawful use of a weapon by a felon (2007) and delivery of 1–15 grams of narcotics (2002), committed when he was 17.
The jury convicted Gray under the armed habitual criminal provision; the trial court sentenced him to nine years’ imprisonment (85% credit rule).
On appeal Gray argued, among other claims, that his juvenile-era narcotics adjudication could not qualify as a predicate conviction under the armed habitual criminal statute because juvenile adjudications are not convictions and changes to juvenile jurisdiction mean the conduct would not be punishable as a felony.
The appellate court held the State failed to prove the required prior convictions because the 2002 juvenile offense would not have been punishable as a felony under the law governing juvenile jurisdiction, and reversed the armed habitual criminal conviction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Gray’s 2002 narcotics conviction (committed at age 17) qualifies as a prior "conviction" under the armed habitual criminal statute (which requires prior convictions for offenses that "is punishable as a Class 3 felony or higher").	The State relied on Gray’s record showing a prior felony conviction and argued prior juvenile convictions transferred to criminal court count as convictions for habitual-offender purposes.	Gray argued juvenile adjudications are not convictions and, under amendments to the Juvenile Court Act, his 2002 offense would have been handled in juvenile court and therefore would not be "punishable" as a Class 3+ felony for purposes of the statute.	The court held the 2002 juvenile conviction does not qualify: juvenile adjudications are not convictions and the conduct would not have been punishable as a felony under current juvenile-jurisdiction rules, so the State failed to prove the required prior convictions.

People v. Taylor, 221 Ill. 2d 157 (Ill. 2006) (juvenile adjudications do not constitute convictions)
Fitzsimmons v. Norgle, 104 Ill. 2d 369 (Ill. 1984) (prior convictions following transfer to criminal court may count for habitual-offender determinations)