People v. Williams, 2016 IL 118375

Adrian Williams pleaded guilty to Class 2 unlawful delivery of cocaine in exchange for a 25‑year cap; he also pleaded guilty to retail theft with a concurrent 5‑year cap.
Williams had prior felony convictions including a prior drug conviction under the Controlled Substances Act (Act) and multiple prior non‑drug felonies that made him eligible for Class X sentencing (6–30 years).
The trial court repeatedly admonished Williams that, absent the plea agreement, his maximum exposure was 60 years — based on treating the Class X 30‑year maximum as doubled under section 408(a) of the Act.
Williams moved to withdraw his guilty plea, arguing the admonition was incorrect and the plea was not knowing/voluntary; the trial court denied the motion.
The appellate court reversed, holding section 408(a) conflicted with section 5‑8‑2(a) of the Unified Code of Corrections and that Williams was prejudiced by the incorrect admonition; the Supreme Court granted review.
The Illinois Supreme Court affirmed the appellate court’s judgment but on different reasoning: it found section 408(a) ambiguous and, under the rule of lenity, construed it to apply only to offenses under the Act (so it could not double the enhanced Class X maximum).

Issue	Plaintiff's Argument (State)	Defendant's Argument (Williams)	Held
Whether 720 ILCS 570/408(a) may double an enhanced Class X maximum (30 → 60 years) when the enhancement derives from the Code (prior non‑drug felonies)	§408(a) applies broadly: "maximum term otherwise authorized" includes the enhanced Class X 30‑year maximum, so it may be doubled to 60 years.	§408(a) should be read to apply only to punishments "otherwise authorized under this Act;" doubling an enhanced Code‑based maximum conflicts with the Code and is barred.	The statute is ambiguous; applying the rule of lenity, §408(a) applies only to offenses under the Act and thus cannot double the enhanced Class X maximum. Appellate judgment affirmed.
Whether Williams was prejudiced by the trial court’s admonition that his maximum exposure was 60 years (impact on voluntariness of plea)	If §408(a) can double the maximum, the admonition might be correct and not prejudicial.	The 60‑year admonition was incorrect and materially misled Williams about the benefit of the plea (he thought he negotiated a larger reduction).	Because the trial court’s admonition that the maximum was 60 years was erroneous under the Court’s construction of §408(a), the appellate court correctly found prejudice; judgment affirmed.

People v. Olivo, 183 Ill.2d 339 (1998) (defendant ineligible for Class X extended term if never previously convicted of a Class X felony)
People v. Pullen, 192 Ill.2d 36 (2000) (trial court denial of motion to withdraw guilty plea reviewed for abuse of discretion)
People v. Jones, 223 Ill.2d 569 (2006) (rule of lenity applies to ambiguous criminal statutes)
People v. McDonough, 239 Ill.2d 260 (2010) (Supreme Court may affirm appellate court judgment for any basis supported by the record)
People v. Marshall, 242 Ill.2d 285 (2011) (statute is ambiguous if reasonably capable of more than one interpretation)