People v. White, 2011 IL 109616

Defendant Pierre White was charged with three counts of first-degree murder, armed robbery, and attempted armed robbery in connection with a 2004 taxi-driver killing.
February–June 2007 plea negotiations led to a plea: guilty to first-degree murder with a 28-year sentence plus a 4-year consecutive term for possession, total 32 years.
The State’s factual basis for the murder alleged use of a firearm and accountability for the shooting.
The trial court accepted the plea and sentenced White to 28 years for murder and 4 years for possession, pursuant to the plea.
White moved to withdraw the guilty plea arguing the 15-year firearm enhancement should apply, making the range 35–75 years and the 28-year sentence invalid.
Appellate Court reversed, holding the plea and sentence void for failure to impose the mandatory 15-year enhancement under 730 ILCS 5/5–8–1(a)(1)(d)(i).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a trial court may impose a sentence omitting a mandatory 15-year firearm enhancement	State argues plea could reflect a lesser, unenhanced term.	White argues the statute requires the 15-year enhancement when firearm use is established.	No; mandatory enhancement must be imposed; sentence void if missing.
Whether the firearm enhancement is triggered by the factual basis showing firearm use in accountability-based murder	State maintains enhancement applies if facts support firearm use.	White contends relying on accountability alone excludes enhancement.	Triggered by facts; enhancement mandatory.
Whether the void sentence invalidates the entire plea and requires withdrawal to proceed to trial	State contends pleas can survive if enhancement not applied.	White seeks withdrawal of plea; sentence and plea void.	Sentence and plea void; remand with option to withdraw plea.

People v. Rodriguez, 229 Ill. 2d 285 (2008) (applies 15-year enhancement to accountability for murder)
People v. Summers, 291 Ill. App. 3d 656 (1997) (Summers principle not applicable where factual basis triggers enhancement)
People v. Keller, 353 Ill. App. 3d 830 (2004) (indicts armed robbery; plea amended to fit enhanced range; illustrates amendment to avoid enhancement)
People v. Arna, 168 Ill. 2d 107 (1995) (void sentence for nonconforming statutory requirement)
People v. Jamison, 197 Ill. 2d 135 (2001) (State’s charging discretion; plea bargaining context)
People v. Whitfield, 228 Ill. 2d 502 (2007) (statutory sentencing guidelines; authority limits on improper sentences)
Pullen, 192 Ill. 2d 36 (2000) (sentence exceeding/failing to comply with statutory ranges voids)
Townsell, 209 Ill. 2d 543 (2004) (Apprendi-based objections in guilty-plea context not heard on appeal)
Brady v. United States, 397 U.S. 742 (1970) (plea bargaining advantages; sentencing flexibility in plea agreements)