People v. Rinehart
2012 IL 111719
Ill.
2012

Background

  • Defendant Thomas Rinehart was convicted of criminal sexual assault in 2007 and sentenced to 28 years’ imprisonment.
  • The appellate court affirmed but remanded to set a term of mandatory supervised release (MSR) within 3 years to natural life under 730 ILCS 5/5-8-1(d)(4).
  • The State appealed, challenging both MSR direction and voir dire issues raised by the defendant.
  • At sentencing, the trial court stated MSR would be determined by the Department of Corrections within the statutory range, not a fixed term.
  • DOC later calculated an indeterminate MSR term of 3 years to natural life, and the defendant appealed the MSR ruling.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether MSR must be determinate within the range Rinehart contends MSR must be fixed within 3 years to natural life. Appellate court held MSR must be determinate; Schneider supported determinate MSR. MSR is indeterminate: 3 years to natural life.
Plain error in voir dire on delayed reporting State argues questions were permissible to uncover bias about delayed reporting. Defense contends the questions improperly preeducated jurors about credibility. There was no reversible error; questions were within trial court’s discretion and not plainly prejudicial.
Effect of 2005 Act on MSR structure Act harmonizes MSR with indeterminate supervision for sex offenses. Act creates conflict with determinate sentence structure for MSR. Statutory scheme supports indeterminate MSR for 5-8-1(d)(4) offenses.

Key Cases Cited

  • People v. Cordell, 223 Ill. 2d 380 (2006) (statutory construction framework and de novo review)
  • People v. Beachem, 229 Ill. 2d 237 (2008) (statutory interpretation and in pari materia guidance)
  • People v. Bell, 152 Ill. App. 3d 1007 (1987) (voir dire improper questions can indoctrinate jurors)
  • People v. Boston, 383 Ill. App. 3d 352 (2008) (voir dire questions about consent and credibility improper)
  • People v. Mapp, 283 Ill. App. 3d 979 (1996) (purpose of voir dire; rational limits of inquiry)
  • People v. Faulkner, 186 Ill. App. 3d 1013 (1989) (limits on targeted voir dire in trials)
  • People v. Dow, 240 Ill. App. 3d 392 (1992) (voir dire as tool to uncover bias; not indoctrination)
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