People v. Kayer, 2013 IL App (4th) 120028

Defendant Brian M. Kayer was charged in July 2011 with unlawful failure to register employment change as a sex offender under 730 ILCS 150/6.
In September 2011, he pleaded guilty to the charge and, in October 2011, the trial court sentenced him to three years’ imprisonment.
The information alleged a change in employment from Interlake Mecalux, Inc. to no longer employed there, within three days after leaving on June 29, 2011.
The State’s factual basis linked the change in employment status to his duty to report under the Registration Act.
The conviction was challenged as void because loss of employment does not constitute a change in place of employment under section 6, and the court vacated the judgment accordingly.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether loss of employment is a change in place of employment under §6	People argues loss constitutes a change in place of employment	Kayer argues it is not a change in place of employment	No; loss of employment is not a change in place of employment; conviction void.
Whether the plea/conviction rests on a criminal offense as defined by the statute	People contends the information adequately alleged an offense	Kayer contends the information is defective and does not allege a criminal offense	Conviction void because information did not allege a crime under §6 (jurisdiction lacking).

People v. McCarty, 94 Ill.2d 28 (1983) (jurisdiction lacking when facts do not allege the offense as defined by statute)
Lesher v. Trent, 407 Ill. App. 3d 1170 (2011) (statutory interpretation and public-safety context)
Malchow v. Malchow, 193 Ill.2d 413 (2000) (statutory interpretation principles in public safety context)
People v. Taylor, 221 Ill.2d 157 (2006) (proper interpretation of statutory terms and plain meaning)
Snyder v. Heidelberger, 2011 IL 111052 (2011) (statutory interpretation standard and approach)