People v. Sophanavong, 121 N.E.3d 516

Defendant Phouvone Sophanavong pled guilty pursuant to a fully negotiated plea to one count of first-degree murder and was sentenced to 55 years (30-year base + 25-year firearm enhancement).
At the plea hearing the State recited a factual basis and mentioned prior convictions (a 2004 Class 1 felony for cannabis and two minor traffic offenses) but did not state the dispositions for those prior convictions.
The parties waived a presentence investigation (PSI) on the record and the trial court accepted the negotiated plea and sentence.
Defendant later filed pro se and counseled motions to withdraw his plea raising ineffective-assistance and voluntariness claims; procedural issues led to remands under Rule 604(d), but he did not challenge the PSI waiver or the lack of disposition information until appeal.
On appeal defendant argued the sentence must be vacated because the trial court failed to strictly comply with 730 ILCS 5/5-3-1 by accepting an agreed sentence without a PSI or adequate information about prior dispositions.
The Third District vacated the sentence and remanded for a new sentencing hearing, holding strict compliance with section 5-3-1 is required and the trial court had no disposition information before accepting the negotiated plea.

Issue	State's Argument	Sophanavong's Argument	Held
Whether the trial court complied with 730 ILCS 5/5-3-1 when it accepted a negotiated guilty plea and imposed sentence without a PSI or dispositions for prior convictions	The negotiated plea remains in effect so defendant cannot challenge the sentence; alternatively, the court had sufficient information about defendant's history to accept the plea	The court lacked required information (no PSI and no dispositions of prior convictions), so section 5-3-1 was not strictly complied with and sentence must be vacated	Sentence vacated and remanded for a new sentencing hearing in strict compliance with section 5-3-1

People v. Youngbey, 82 Ill. 2d 556 (establishes PSI requirement is mandatory and generally cannot be waived)
People v. Walton, 357 Ill. App. 3d 819 (failure to strictly comply with section 5-3-1 requires vacatur and remand for resentencing)
People v. Harris, 105 Ill. 2d 290 (strict compliance with statutory sentencing procedures is required)