single-subject rule in Illinois

2026Aug. 20, 1995), but in Reedy, 186 Ill. 2d 1 (1999), our supreme court held that Public Act 89-404 violated the single-subject rule of the Illinois Constitution and was, therefore, “unconstitutional in its entirety.” Reedy, 186 Ill. 2d at 11-12 .

2026Also, according to the defendant, his 70-year prison sentence was void because our supreme court had held in People v. Reedy, 186 Ill. 2d 1 (1999), that the truth-in-sentencing law was “unconstitutional, invalid, and void” due to its being enacted in violation of the Illinois Constitution’s single-subject clause (Ill. Const. 1970, art.

2025In Johnson v. Edgar, 176 Ill. 2d 499, 518, 523 (1997) our supreme court held that Public Act 89-428 violated the single-subject rule of the Illinois Constitution (Ill. Const. 1970, art.

2024However, Public Act 89-428 was later held unconstitutional in Johnson v. Edgar, 176 Ill. 2d 499 (1997), as violating the single-subject clause.

2023Thus, when the supreme court in Cervantes struck down the public act as facially unconstitutional for violating the single-subject rule (Cervantes, 189 Ill. 2d at 98 ), the provision under which defendant was convicted remained unchanged.

2011Jan. 1, 1995)), which our supreme court found unconstitutional in People v. Cervantes, 189 Ill. 2d 80, 89 (1999), because it violated the single-subject rule.

2016Id. at 14-15 . ¶ 25 Our supreme court thus refused to apply the good-faith exception to the defendant’s case, concluding that to do so “would run counter to our single-subject clause and void ab initio jurisprudence–specifically, that once a statute is declared facially unconstitutional, it is as if it had never been enacted.” Id. at 16 .

2016Id. at 3, 8, 16 .

2021Although it is true the supreme court found Public Acts 89-428 and 89-203 void as violative of the single-subject rule in Johnson v. Edgar, 176 Ill. 2d 499, 518 , 680 N.E.2d 1372, 1381 (1997), and People v. Wooters, 188 Ill. 2d 500 , 514, 722 N.E.2d 1102 , 1110 (1999), respectively, these findings have no relation to defendant’s conviction and sentence.

2021Although it is true the supreme court found Public Acts 89-428 and 89-203 void as violative of the single-subject rule in Johnson v. Edgar, 176 Ill. 2d 499, 518 , 680 N.E.2d 1372, 1381 (1997), and People v. Wooters, 188 Ill. 2d 500 , 514, 722 N.E.2d 1102 , 1110 (1999), respectively, these findings have no relation to defendant’s conviction and sentence.

2004If that purpose is permitted to be defined broadly, as it is under a single-subject analysis for instance (see People v. Burdunice, 211 Ill. 2d 264, 269 , 811 N.E.2d 678 (2004) (stating that “criminal law” qualifies as a legitimate single subject for a statute)), then all criminal statutes will qualify for cross-comparison analysis.

2004If that purpose is permitted to be defined broadly, as it is under a single-subject analysis for instance (see People v. Burdunice, 211 Ill. 2d 264, 269 , 811 N.E.2d 678 (2004) (stating that “criminal law” qualifies as a legitimate single subject for a statute)), then all criminal statutes will qualify for cross-comparison analysis.

2025IV, § 8) and was therefore unconstitutional. 189 Ill. 2d at 98 . ¶ 27 In Brown, 225 Ill. 2d 188 , our supreme court discussed the consequences of Public Act 88-680 being held unconstitutional.

2010People v. Brown, 225 Ill. 2d 188, 198 (2007).

1995See Fuehrmeyer v. City of Chicago (1974), 57 Ill. 2d 193 (examination of journals, in violation of the enrolled-bill rule, not necessary because statute, on its face, clearly violated the single-subject requirement).

1995See Fuehrmeyer v. City of Chicago (1974), 57 Ill.2d 193 , 311 N.E.2d 116 (examination of journals, in violation of the enrolled-bill rule, not necessary because statute, on its face, clearly violated the single-subject requirement).

2007Although successive postconviction petitions are generally not permitted (see 725 ILCS 5/122 — 3 (West 1998)), defendant argued that fundamental fairness called for relaxation of that rule in this case (see People v. Morgan, 212 Ill. 2d 148, 153 (2004)) because the Safe Neighborhoods Law, which added the rebuttable presumption provision under which he was transferred to criminal court, had since been declared unconstitutional and void ab initio by our court in People v. Cervantes, 189 Ill. 2d 80 (1999), on the grounds that it violated the single-subject clause of the Illinois Constitution of 1

2007Although successive postconviction petitions are generally not permitted (see 725 ILCS 5/122–3 (West 1998)), defendant argued that fundamental fairness called for relaxation of that rule in this case (see People v. Morgan, 212 Ill. 2d 148, 153 (2004)) because the Safe Neighborhoods Law, which added the rebuttable presumption provision under which he was transferred to criminal court, had since been declared unconstitutional and void ab initio by our court in People v. Cervantes, 189 Ill. 2d 80 (1999), on the grounds that it violated the single-subject clause of the Illinois Constitution of 197

2005See People v. Terry, 329 Ill.

2005See People v. Terry , 329 Ill.

2005Arangold Corp. v. Zehnder, 187 Ill. 2d 341, 352 , 718 N.E.2d 191, 198 (1999) (Arangold I).

2005Arangold Corp. v. Zehnder, 187 Ill. 2d 341, 352 , 718 N.E.2d 191, 198 (1999) (Arangold I).

2002People v. Vilces , 321 Ill.

2002People v. Vilces, 321 Ill.

1987Accord, Schlenz v. Castle (1981), 84 Ill. 2d 196 ; People ex rel.

1986See also Schlenz v. Castle (1981), 84 Ill. 2d 196, 209-11 (applying Carey to amendments to the Revenue Act of 1939).

2021See People v. Reedy, 295 Ill. App. 3d 34 (1998); People v. Pitts, 295 Ill. App. 3d 182 (1998).

1999Reedy, 295 Ill.

2023People v. Tellez-Valencia, 188 Ill. 2d 523, 525-26 , 723 N.E.2d 223, 224-25 (1999).

2023People v. Tellez-Valencia, 188 Ill. 2d 523, 525-26 , 723 N.E.2d 223, 224-25 (1999).

2021See People v. Smith, 314 Ill.