People v. Wallace, 2025 IL 130173

Deshawn Wallace was convicted in 2019 of being an armed habitual criminal after being found in possession of a firearm during a lawful vehicle stop.
The conviction required proof that Wallace had at least two prior qualifying (predicate) felony convictions.
The State used Wallace's 2008 armed robbery conviction (when he was 17) and a 2015 unlawful use of a weapon by a felon conviction as predicate felonies.
In 2014, Illinois law changed to make most 17-year-olds eligible for juvenile court, raising the question of whether his 2008 offense would be treated as a juvenile adjudication under current law.
Wallace argued on appeal that because his 2008 offense would have been a juvenile adjudication under 2019 laws, it could not serve as a predicate felony for his 2019 conviction under the armed habitual criminal statute.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Wallace’s 2008 conviction (at 17) can serve as a predicate felony for an armed habitual criminal conviction in 2019	Wallace: The 2008 conviction would be a juvenile adjudication under current law, not a felony conviction; therefore, it cannot serve as a predicate offense.	State: The armed habitual criminal statute only requires prior qualifying convictions, regardless of current law or the defendant's age at the time of the predicate offense.	Yes; the 2008 conviction counts as a predicate offense under the plain language of the armed habitual criminal statute.