People v. Stewart, 215 N.E.3d 752

In 2016 defendant Denzal Stewart (then 20) committed possession of a stolen motor vehicle; he was convicted in 2017 after turning 21 and sentenced as a Class X offender to six years’ imprisonment.
The trial court relied on two prior felony convictions introduced by the State: a 2013 residential burglary (defendant was 17 at that time) and a 2014 possession of a stolen motor vehicle.
Defendant challenged Class X eligibility on appeal, arguing his 2013 offense would have been a juvenile adjudication if committed on the date of the present offense and therefore could not qualify as a prior "conviction."
The appellate court held the 2013 conviction was not a qualifying predicate under 730 ILCS 5/5-4.5-95(b) and remanded for resentencing as a Class 2 offender.
The Supreme Court affirmed the appellate court, concluding the 2013 offense did not qualify for Class X sentencing; it relied in part on a subsequent legislative amendment (Public Act 101-652) clarifying that qualifying prior offenses must have been committed at age 21 or older.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Stewart)	Held
Whether the 2013 residential burglary (age 17) is a qualifying prior conviction for Class X sentencing under 730 ILCS 5/5-4.5-95(b)	The statute looks to whether the prior offense’s elements match an offense that is a Class 2+ as of the date of the present offense; age is not an element, so the 2013 conviction qualifies	If the 2013 offense would have been resolved in juvenile court on the date of the present offense, it would not have produced a conviction and therefore cannot serve as a qualifying prior	The court held the 2013 conviction did not qualify; the subsequent amendment to the statute (Public Act 101-652) confirms the legislative intent to exclude juvenile convictions as predicates
Whether the sentencing error is reviewable despite forfeiture (plain error)	The State did not preserve the issue but argues sentencing was proper	Stewart asserted plain error and alternative ineffective assistance arguments	The court treated the statutory-ineligibility as plain error under the second prong (unauthorized sentence affects substantial rights) and affirmed vacatur of the Class X sentence

People v. Belknap, 2014 IL 117094 (sets two-pronged plain-error standard)
People v. Fort, 2017 IL 118966 (unauthorized sentence affects substantial rights)
People v. Roberts, 214 Ill.2d 106 (statutory interpretation focuses on legislative intent)
People v. Marshall, 242 Ill.2d 285 (apply plain meaning when statute unambiguous)
K. Miller Constr. Co. v. McGinnis, 238 Ill.2d 284 (post-enactment amendment may illuminate legislative intent)
Ready v. United/Goedecke Servs., Inc., 232 Ill.2d 369 (conflicting lower-court interpretations do not alone create ambiguity)
People v. Clark, 2019 IL 122891 (courts must apply statute as written when unambiguous)
In re Detention of Lieberman, 201 Ill.2d 300 (use of subsequent amendment for intent analysis)
Carey v. Elrod, 49 Ill.2d 464 (amendment-as-interpretation precedent)