People v. King, 241 Ill. 2d 374

Defendant Ricky King, age 15 at the time, was charged with five counts of first degree murder for the August 8, 2002 beating death of Robert Nash.
The State later added an attempted first degree murder count arising from the same incident; on the same day, King pled guilty to the attempted murder in exchange for dismissal of the murder charges and a 15-year sentence.
King moved pro se in 2008 under the Post-Conviction Hearing Act, challenging admonishments about mandatory supervised release; the petition was dismissed as frivolous.
On appeal, King argued for the first time that his sentence was void because the State failed to request a hearing under section 5-130(1)(c)(ii) of the Juvenile Court Act to determine adult sentencing.
The appellate court agreed and reversed, remanding with instructions to vacate the conviction, adjudicate delinquency, and sentence under the Act to time served as of age 21.
This court granted review to interpret sections 5-130(1)(a)-(c) of the Act and determine whether the offense was “covered by” 5-130(1)(a) and whether a hearing was required for adult sentencing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether 'covered by' 5-130(1)(a) includes only 'specified' charges or all charges arising from the same incident	King argued covered is limited to specified offenses	State argued covered includes all charges arising from the same incident	Covered includes all charges arising from the same incident
Whether a hearing was required under 5-130(1)(c)(ii) or whether sentencing could proceed under 5-130(1)(c)(i) without a hearing	King contends a hearing was required to sentence as an adult	State argues no hearing needed where offense is covered by 5-130(1)(a) and sentenced under (c)(i)	Sentencing without a hearing was proper under (c)(i) because the offense was covered by (a)

People v. J.S., 103 Ill.2d 395 (1984) (juvenile proceedings framework; charging instrument governs juvenile status)
People v. Hudson, 228 Ill.2d 181 (2008) (different meanings may be intended by statute's distinct terms)
People v. Jardon, 393 Ill.App.3d 725 (2009) (discussed 5-130 interpretation and adult sentencing hearings)
People v. Mathis, 357 Ill.App.3d 45 (2005) (juvenile court sentencing framework in multi-charge cases)
People v. Champ, 329 Ill.App.3d 127 (2002) (application of 5-130 to juvenile prosecutions)
People v. Brazee, 333 Ill.App.3d 43 (2002) (interpretation of charges and proceedings under 5-130)
People v. Brazee, 316 Ill.App.3d 1230 (2000) (earlier interpretation guiding subsequent 5-130 analysis)