People v. Horsman, 406 Ill. App. 3d 984

People of Illinois charged Horsman with a fourth or subsequent violation of driving with license revoked, a Class 4 felony.
Horsman pleaded guilty to the charge open, acknowledging prior violations and DUI-related revocation.
At sentencing, Horsman requested electronic home monitoring as the imprisonment substitute; the trial court rejected this and imposed 180 days in jail with work release.
The court later denied a motion to reconsider; Horsman appealed challenging the rejection of electronic home monitoring.
The appellate court addressed whether ‘imprisonment’ in 6-303(d-3) includes electronic home detention and concluded the term is ambiguous, then applied extrinsic aids to interpret legislative intent, ultimately affirming the jail sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Can electronic home detention satisfy imprisonment under 6-303(d-3)?	Horsman	Horsman	Imprisonment ambiguous; actual incarceration required
Should the public-interest mootness exception permit consideration of the merits?	People	Horsman	Public-interest exception applies; merits considered

People v. Moss, 274 Ill. App. 3d 77 (1995) (electronic home detention previously treated as confinement, not full imprisonment)
People v. Moncrief, 276 Ill. App. 3d 533 (1995) (parolee on electronic monitoring could affect sentencing outcomes)
Stocke v. People, 212 Ill. App. 3d 547 (1991) (home confinement not equivalent to imprisonment)
Hadley v. Montes, 379 Ill. App. 3d 405 (2008) (electronic monitoring not punishment; not equivalent to imprisonment)
In re Alfred H.H., 233 Ill. 2d 345 (2009) (public interest exception to mootness; broad public significance)
Felzak v. Hruby, 226 Ill. 2d 382 (2007) (public interest exception and advisory opinions for public guidance)
People v. Campa, 217 Ill. 2d 243 (2005) (sentence to county jail is incarceration; supports distinction from electronic monitoring)