People v. Smith, 2016 IL 119659

Matthew Smith, born Sept. 24, 1991, was indicted for aggravated battery of a corrections officer for throwing an unknown liquid on Officer Jody Davis; jury convicted and trial court sentenced him as a Class X offender to six years.
The State filed notice seeking mandatory Class X sentencing under 730 ILCS 5/5-4.5-95(b) based on two prior qualifying felonies (Oct. 2007 and June 2010).
Smith was 19 at the time of the offense, 20 at indictment, and 21 at trial and sentencing.
Smith waived counsel, moved to suppress a post-incident confession to Officer Robert Snyder (an Internal Affairs investigator); the trial court denied suppression, finding the interview investigatory (not custodial) and Miranda not required.
The appellate court affirmed the conviction, but held Smith ineligible for Class X sentencing because he was not over 21 at the time he was charged; it vacated the sentence and remanded for resentencing.
The Illinois Supreme Court granted leave, reversed the appellate court as to sentencing (holding eligibility depends on being over 21 at conviction), and affirmed denial of the suppression motion.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Smith)	Held
Whether eligibility for mandatory Class X sentencing under 730 ILCS 5/5-4.5-95(b) depends on the defendant being over 21 at conviction (or at charging/commission)	Statute applies when defendant is over 21 at conviction; Smith was 21 at conviction so Class X applies	Statute ambiguous; age must be >21 when charged (or when offense committed); Smith was 20 at indictment so ineligible	Held: Plain language requires defendant be over 21 at conviction; Smith was 21 at conviction, so Class X sentence proper (appellate court reversed on this point)
Whether Miranda warnings were required for Smith’s statements to Officer Snyder (i.e., whether interrogation was custodial)	Interview was investigatory, noncustodial (Smith in segregation routinely handcuffed for moves; interview brief; officer alone; defendant free to leave)	Interrogation was custodial (handcuffed, uniformed officer, focused questioning about offense, possible disciplinary consequences), so Miranda required and failure to give warnings was reversible error	Held: Totality of circumstances shows interview was noncustodial; Miranda not required; trial court did not err and suppression denial affirmed

People v. Patterson, 146 Ill. 2d 445 (1992) (factors for custodial interrogation of inmates; held noncustodial where questioning increased freedom of movement relative to segregation)
People v. Easley, 148 Ill. 2d 281 (1992) (applied custodial-interrogation analysis to inmate; Miranda required where handcuffed, multiple investigators, suspect status asserted)
People v. Baaree, 315 Ill. App. 3d 1049 (2000) (held statute ambiguous as to meaning of "convicted" and construed defendant-friendly to treat conviction as adjudication of guilt)
People v. Williams, 358 Ill. App. 3d 363 (2005) (followed Baaree, treating defendant's age at conviction as the relevant time for sentence enhancement)
People v. Stokes, 392 Ill. App. 3d 335 (2009) (applied Baaree/Williams approach; age at conviction governs eligibility)
People v. Chenoweth, 2015 IL 116898 (2015) (statutory interpretation reviewed de novo; primary rule to give effect to plain language of statute)
People v. Luedemann, 222 Ill. 2d 530 (2006) (review standard for suppression rulings: deference to trial court factual findings, de novo review of legal ruling)
People v. Cosby, 231 Ill. 2d 262 (2008) (plain-error doctrine explained: review requires first determining whether error occurred)
People v. Belknap, 2014 IL 117094 (2014) (articulated two-prong framework for plain-error review)