People v. Gray, 2024 IL 127815

Demetrius Gray was charged with, and ultimately convicted of, being an armed habitual criminal following a 2016 incident where he was found in possession of a handgun in Chicago.
The prosecution's case relied, in part, on a stipulation that Gray had two prior qualifying felony convictions necessary for the charge.
The two predicates referenced were a 2008 unlawful use of a weapon by a felon and a 2002 conviction for manufacture or delivery of a controlled substance.
On appeal, Gray argued, and the appellate court agreed, that the 2002 conviction should not qualify because he was 17 at the time, and recent changes to Illinois juvenile law would have treated him as a juvenile (not an adult) for that offense if committed today.
The State appealed, arguing the stipulation was sufficient to prove the required elements and that Gray could not dispute facts he had stipulated to at trial.
The Illinois Supreme Court granted review, reversed the appellate decision, and remanded the case for further proceedings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of Evidence for Predicate Convictions	Stipulation at trial that defendant had two qualifying felonies fulfills State's burden	One predicate was invalid, as Gray would have been prosecuted as a juvenile under current law	Stipulation is conclusive, satisfies proof of prior convictions
Effect of Stipulation	Conclusive evidence—defendant cannot contest stipulated facts later	Stipulation should not bind if it rests on a legal error regarding age and qualifying convictions	Defendant barred from contesting stipulated facts on direct sufficiency grounds
Ineffective Assistance of Counsel	No prejudice since other qualifying convictions existed that could have supported the charge	Stipulation was unreasonable, and prejudiced Gray if 2002 conviction was not qualifying	No prejudice—the outcome would likely be the same due to other convictions
Applicability of Changes in Juvenile Law (2014 amendments)	Irrelevant to the already-entered adult felony conviction	2002 conviction wouldn't be an adult felony under current law, thus not qualifying	Declined to reach; sufficiency resolved on stipulation alone

People v. Woods, 214 Ill. 2d 455 (2005) (stipulations are conclusive as to all matters included and obviate the need for proof)
People v. Polk, 19 Ill. 2d 310 (1960) (defendant cannot complain about facts stipulated into the record)
People v. Villarreal, 198 Ill. 2d 209 (2001) (waiver and acquiescence to evidence by stipulation preclude appeal on that ground)