Illinois Compiled Statutes
720 ILCS 5/36-1 (2026)
Property subject to forfeiture
✓ current as of May 2026
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(720 ILCS 5/36-1)
(from Ch. 38, par. 36-1) (Text of Section from P.A. 103-1071) Sec. 36-1. Property subject to forfeiture. (a) Any vessel or watercraft, vehicle, or aircraft is subject to forfeiture under this Article if the vessel or watercraft, vehicle, or aircraft is used with the knowledge and consent of the owner in the commission of or in the attempt to commit as defined in Section 8-4 of this Code: (1) an offense prohibited by Section 9-1 (first | degree murder), Section 9-3 (involuntary manslaughter and reckless homicide), Section 10-2 (aggravated kidnaping), Section 11-1.20 (criminal sexual assault), Section 11-1.30 (aggravated criminal sexual assault), Section 11-1.40 (predatory criminal sexual assault of a child), subsection (a) of Section 11-1.50 (criminal sexual abuse), subsection (a), (c), or (d) of Section 11-1.60 (aggravated criminal sexual abuse), Section 11-6 (indecent solicitation of a child), Section 11-14.4 (promoting commercial sexual exploitation of a child except for keeping a place of commercial sexual exploitation of a child), Section 11-20.1 (child pornography), paragraph (a)(1), (a)(2), (a)(4), (b)(1), (b)(2), (e)(1), (e)(2), (e)(3), (e)(4), (e)(5), (e)(6), or (e)(7) of Section 12-3.05 (aggravated battery), Section 12-7.3 (stalking), Section 12-7.4 (aggravated stalking), Section 16-1 (theft if the theft is of precious metal or of scrap metal), subdivision (f)(2) or (f)(3) of Section 16-25 (retail theft), Section 18-2 (armed robbery), Section 19-1 (burglary), Section 19-2 (possession of burglary tools), Section 19-3 (residential burglary), Section 20-1 (arson; residential arson; place of worship arson), Section 20-2 (possession of explosives or explosive or incendiary devices), subdivision (a)(6) or (a)(7) of Section 24-1 (unlawful use of weapons), Section 24-1.2 (aggravated discharge of a firearm), Section 24-1.2-5 (aggravated discharge of a machine gun or a firearm equipped with a device designed or used for silencing the report of a firearm), Section 24-1.5 (reckless discharge of a firearm), Section 28-1 (gambling), or Section 29D-15.2 (possession of a deadly substance) of this Code; |
(2) an offense prohibited by Section 21, 22, 23, 24 | or 26 of the Cigarette Tax Act if the vessel or watercraft, vehicle, or aircraft contains more than 10 cartons of such cigarettes; |
(3) an offense prohibited by Section 28, 29, or 30 of | the Cigarette Use Tax Act if the vessel or watercraft, vehicle, or aircraft contains more than 10 cartons of such cigarettes; |
(4) an offense prohibited by Section 44 of the | Environmental Protection Act; |
(5) an offense prohibited by Section 11-204.1 of the | Illinois Vehicle Code (aggravated fleeing or attempting to elude a peace officer); |
(6) an offense prohibited by Section 11-501 of the | Illinois Vehicle Code (driving while under the influence of alcohol or other drug or drugs, intoxicating compound or compounds or any combination thereof) or a similar provision of a local ordinance, and: |
(A) during a period in which his or her driving | privileges are revoked or suspended if the revocation or suspension was for: |
(i) Section 11-501 (driving under the | influence of alcohol or other drug or drugs, intoxicating compound or compounds or any combination thereof), |
(ii) Section 11-501.1 (statutory summary | suspension or revocation), |
(iii) paragraph (b) of Section 11-401 (motor | vehicle crashes involving death or personal injuries), or |
(iv) reckless homicide as defined in Section | 9-3 of this Code; |
(B) has been previously convicted of reckless | homicide or a similar provision of a law of another state relating to reckless homicide in which the person was determined to have been under the influence of alcohol, other drug or drugs, or intoxicating compound or compounds as an element of the offense or the person has previously been convicted of committing a violation of driving under the influence of alcohol or other drug or drugs, intoxicating compound or compounds or any combination thereof and was involved in a motor vehicle crash that resulted in death, great bodily harm, or permanent disability or disfigurement to another, when the violation was a proximate cause of the death or injuries; |
(C) the person committed a violation of driving | under the influence of alcohol or other drug or drugs, intoxicating compound or compounds or any combination thereof under Section 11-501 of the Illinois Vehicle Code or a similar provision for the third or subsequent time; |
(D) he or she did not possess a valid driver's | license or permit or a valid restricted driving permit or a valid judicial driving permit or a valid monitoring device driving permit; or |
(E) he or she knew or should have known that the | vehicle he or she was driving was not covered by a liability insurance policy; |
(7) an offense described in subsection (g) of Section | 6-303 of the Illinois Vehicle Code; |
(8) an offense described in subsection (e) of Section | 6-101 of the Illinois Vehicle Code; or |
(9)(A) operating a watercraft under the influence of | alcohol, other drug or drugs, intoxicating compound or compounds, or combination thereof under Section 5-16 of the Boat Registration and Safety Act during a period in which his or her privileges to operate a watercraft are revoked or suspended and the revocation or suspension was for operating a watercraft under the influence of alcohol, other drug or drugs, intoxicating compound or compounds, or combination thereof; (B) operating a watercraft under the influence of alcohol, other drug or drugs, intoxicating compound or compounds, or combination thereof and has been previously convicted of reckless homicide or a similar provision of a law in another state relating to reckless homicide in which the person was determined to have been under the influence of alcohol, other drug or drugs, intoxicating compound or compounds, or combination thereof as an element of the offense or the person has previously been convicted of committing a violation of operating a watercraft under the influence of alcohol, other drug or drugs, intoxicating compound or compounds, or combination thereof and was involved in an accident that resulted in death, great bodily harm, or permanent disability or disfigurement to another, when the violation was a proximate cause of the death or injuries; or (C) the person committed a violation of operating a watercraft under the influence of alcohol, other drug or drugs, intoxicating compound or compounds, or combination thereof under Section 5-16 of the Boat Registration and Safety Act or a similar provision for the third or subsequent time. |
(b) In addition, any mobile or portable equipment used in the commission of an act which is in violation of Section 7g of the Metropolitan Water Reclamation District Act shall be subject to seizure and forfeiture under the same procedures provided in this Article for the seizure and forfeiture of vessels or watercraft, vehicles, and aircraft, and any such equipment shall be deemed a vessel or watercraft, vehicle, or aircraft for purposes of this Article. (c) In addition, when a person discharges a firearm at another individual from a vehicle with the knowledge and consent of the owner of the vehicle and with the intent to cause death or great bodily harm to that individual and as a result causes death or great bodily harm to that individual, the vehicle shall be subject to seizure and forfeiture under the same procedures provided in this Article for the seizure and forfeiture of vehicles used in violations of clauses (1), (2), (3), or (4) of subsection (a) of this Section. (d) If the spouse of the owner of a vehicle seized for an offense described in subsection (g) of Section 6-303 of the Illinois Vehicle Code, a violation of subdivision (d)(1)(A), (d)(1)(D), (d)(1)(G), (d)(1)(H), or (d)(1)(I) of Section 11-501 of the Illinois Vehicle Code, or Section 9-3 of this Code makes a showing that the seized vehicle is the only source of transportation and it is determined that the financial hardship to the family as a result of the seizure outweighs the benefit to the State from the seizure, the vehicle may be forfeited to the spouse or family member and the title to the vehicle shall be transferred to the spouse or family member who is properly licensed and who requires the use of the vehicle for employment or family transportation purposes. A written declaration of forfeiture of a vehicle under this Section shall be sufficient cause for the title to be transferred to the spouse or family member. The provisions of this paragraph shall apply only to one forfeiture per vehicle. If the vehicle is the subject of a subsequent forfeiture proceeding by virtue of a subsequent conviction of either spouse or the family member, the spouse or family member to whom the vehicle was forfeited under the first forfeiture proceeding may not utilize the provisions of this paragraph in another forfeiture proceeding. If the owner of the vehicle seized owns more than one vehicle, the procedure set out in this paragraph may be used for only one vehicle. (e) In addition, property subject to forfeiture under Section 40 of the Illinois Streetgang Terrorism Omnibus Prevention Act may be seized and forfeited under this Article.(Source: P.A. 102-982, eff. 7-1-23; 103-1071, eff. 7-1-25.) (Text of Section from P.A. 104-245) Sec. 36-1. Property subject to forfeiture. (a) Any vessel or watercraft, vehicle, or aircraft is subject to forfeiture under this Article if the vessel or watercraft, vehicle, or aircraft is used with the knowledge and consent of the owner in the commission of or in the attempt to commit as defined in Section 8-4 of this Code: (1) an offense prohibited by Section 9-1 (first | degree murder), Section 9-3 (involuntary manslaughter and reckless homicide), Section 10-2 (aggravated kidnaping), Section 11-1.20 (criminal sexual assault), Section 11-1.30 (aggravated criminal sexual assault), Section 11-1.40 (predatory criminal sexual assault of a child), subsection (a) of Section 11-1.50 (criminal sexual abuse), subsection (a), (c), or (d) of Section 11-1.60 (aggravated criminal sexual abuse), Section 11-6 (indecent solicitation of a child), Section 11-14.4 (promoting juvenile prostitution except for keeping a place of juvenile prostitution), Section 11-20.1 (child sexual abuse material), paragraph (a)(1), (a)(2), (a)(4), (b)(1), (b)(2), (e)(1), (e)(2), (e)(3), (e)(4), (e)(5), (e)(6), or (e)(7) of Section 12-3.05 (aggravated battery), Section 12-7.3 (stalking), Section 12-7.4 (aggravated stalking), Section 16-1 (theft if the theft is of precious metal or of scrap metal), subdivision (f)(2) or (f)(3) of Section 16-25 (retail theft), Section 18-2 (armed robbery), Section 19-1 (burglary), Section 19-2 (possession of burglary tools), Section 19-3 (residential burglary), Section 20-1 (arson; residential arson; place of worship arson), Section 20-2 (possession of explosives or explosive or incendiary devices), subdivision (a)(6) or (a)(7) of Section 24-1 (unlawful possession of weapons), Section 24-1.2 (aggravated discharge of a firearm), Section 24-1.2-5 (aggravated discharge of a machine gun or a firearm equipped with a device designed or used for silencing the report of a firearm), Section 24-1.5 (reckless discharge of a firearm), Section 28-1 (gambling), or Section 29D-15.2 (possession of a deadly substance) of this Code; |
(2) an offense prohibited by Section 21, 22, 23, 24 | or 26 of the Cigarette Tax Act if the vessel or watercraft, vehicle, or aircraft contains more than 10 cartons of such cigarettes; |
(3) an offense prohibited by Section 28, 29, or 30 of | the Cigarette Use Tax Act if the vessel or watercraft, vehicle, or aircraft contains more than 10 cartons of such cigarettes; |
(4) an offense prohibited by Section 44 of the | Environmental Protection Act; |
(5) an offense prohibited by Section 11-204.1 of the | Illinois Vehicle Code (aggravated fleeing or attempting to elude a peace officer); |
(6) an offense prohibited by Section 11-501 of the | Illinois Vehicle Code (driving while under the influence of alcohol or other drug or drugs, intoxicating compound or compounds or any combination thereof) or a similar provision of a local ordinance, and: |
(A) during a period in which his or her driving | privileges are revoked or suspended if the revocation or suspension was for: |
(i) Section 11-501 (driving under the | influence of alcohol or other drug or drugs, intoxicating compound or compounds or any combination thereof), |
(ii) Section 11-501.1 (statutory summary | suspension or revocation), |
(iii) paragraph (b) of Section 11-401 (motor | vehicle crashes involving death or personal injuries), or |
(iv) reckless homicide as defined in Section | 9-3 of this Code; |
(B) has been previously convicted of reckless | homicide or a similar provision of a law of another state relating to reckless homicide in which the person was determined to have been under the influence of alcohol, other drug or drugs, or intoxicating compound or compounds as an element of the offense or the person has previously been convicted of committing a violation of driving under the influence of alcohol or other drug or drugs, intoxicating compound or compounds or any combination thereof and was involved in a motor vehicle crash that resulted in death, great bodily harm, or permanent disability or disfigurement to another, when the violation was a proximate cause of the death or injuries; |
(C) the person committed a violation of driving | under the influence of alcohol or other drug or drugs, intoxicating compound or compounds or any combination thereof under Section 11-501 of the Illinois Vehicle Code or a similar provision for the third or subsequent time; |
(D) he or she did not possess a valid driver's | license or permit or a valid restricted driving permit or a valid judicial driving permit or a valid monitoring device driving permit; or |
(E) he or she knew or should have known that the | vehicle he or she was driving was not covered by a liability insurance policy; |
(7) an offense described in subsection (g) of Section | 6-303 of the Illinois Vehicle Code; |
(8) an offense described in subsection (e) of Section | 6-101 of the Illinois Vehicle Code; or |
(9)(A) operating a watercraft under the influence of | alcohol, other drug or drugs, intoxicating compound or compounds, or combination thereof under Section 5-16 of the Boat Registration and Safety Act during a period in which his or her privileges to operate a watercraft are revoked or suspended and the revocation or suspension was for operating a watercraft under the influence of alcohol, other drug or drugs, intoxicating compound or compounds, or combination thereof; (B) operating a watercraft under the influence of alcohol, other drug or drugs, intoxicating compound or compounds, or combination thereof and has been previously convicted of reckless homicide or a similar provision of a law in another state relating to reckless homicide in which the person was determined to have been under the influence of alcohol, other drug or drugs, intoxicating compound or compounds, or combination thereof as an element of the offense or the person has previously been convicted of committing a violation of operating a watercraft under the influence of alcohol, other drug or drugs, intoxicating compound or compounds, or combination thereof and was involved in an accident that resulted in death, great bodily harm, or permanent disability or disfigurement to another, when the violation was a proximate cause of the death or injuries; or (C) the person committed a violation of operating a watercraft under the influence of alcohol, other drug or drugs, intoxicating compound or compounds, or combination thereof under Section 5-16 of the Boat Registration and Safety Act or a similar provision for the third or subsequent time. |
(b) In addition, any mobile or portable equipment used in the commission of an act which is in violation of Section 7g of the Metropolitan Water Reclamation District Act shall be subject to seizure and forfeiture under the same procedures provided in this Article for the seizure and forfeiture of vessels or watercraft, vehicles, and aircraft, and any such equipment shall be deemed a vessel or watercraft, vehicle, or aircraft for purposes of this Article. (c) In addition, when a person discharges a firearm at another individual from a vehicle with the knowledge and consent of the owner of the vehicle and with the intent to cause death or great bodily harm to that individual and as a result causes death or great bodily harm to that individual, the vehicle shall be subject to seizure and forfeiture under the same procedures provided in this Article for the seizure and forfeiture of vehicles used in violations of clauses (1), (2), (3), or (4) of subsection (a) of this Section. (d) If the spouse of the owner of a vehicle seized for an offense described in subsection (g) of Section 6-303 of the Illinois Vehicle Code, a violation of subdivision (d)(1)(A), (d)(1)(D), (d)(1)(G), (d)(1)(H), or (d)(1)(I) of Section 11-501 of the Illinois Vehicle Code, or Section 9-3 of this Code makes a showing that the seized vehicle is the only source of transportation and it is determined that the financial hardship to the family as a result of the seizure outweighs the benefit to the State from the seizure, the vehicle may be forfeited to the spouse or family member and the title to the vehicle shall be transferred to the spouse or family member who is properly licensed and who requires the use of the vehicle for employment or family transportation purposes. A written declaration of forfeiture of a vehicle under this Section shall be sufficient cause for the title to be transferred to the spouse or family member. The provisions of this paragraph shall apply only to one forfeiture per vehicle. If the vehicle is the subject of a subsequent forfeiture proceeding by virtue of a subsequent conviction of either spouse or the family member, the spouse or family member to whom the vehicle was forfeited under the first forfeiture proceeding may not utilize the provisions of this paragraph in another forfeiture proceeding. If the owner of the vehicle seized owns more than one vehicle, the procedure set out in this paragraph may be used for only one vehicle. (e) In addition, property subject to forfeiture under Section 40 of the Illinois Streetgang Terrorism Omnibus Prevention Act may be seized and forfeited under this Article.(Source: P.A. 103-822, eff. 1-1-25; 104-245, eff. 1-1-26.) Notes of Decisions
Cited in 29
cases (6 in the last 5 years), 1993–2026 · leading case: People ex rel. Hartrich v. 2010 Harley-Davidson, 2018 IL 121636 (Ill. 2018).
People ex rel. Hartrich v. 2010 Harley-Davidson, 2018 IL 121636 (Ill. 2018). “Those facts showed that her husband was driving on a revoked license while under the influence of alcohol after an earlier revocation was extended due to his prior conviction for driving while his license was revoked, following multiple driving under the influence (DUI)…”
People v. One 1998 GMC, 2011 IL 110236 (Ill. 2011). “OPINION ¶1 The issue presented in this case is whether the vehicle-forfeiture provisions of the Criminal Code of 1961 (the Criminal Code) (720 ILCS 5/36-1 through 36-4 (West 2006)) are facially unconstitutional as a violation of procedural due process because they do not include…”
People ex rel. Hartrich v. 2010 Harley-Davidson, 2018 IL 121636 (Ill. 2018). “¶2 After the trial court ordered the forfeiture of the claimant’s motorcycle based on her husband’s criminal conduct while driving it, she first raised an as-applied constitutional challenge to the Illinois civil forfeiture statute (720 ILCS 5/36-1 (West 2012)). She argued that…”
People v. ONE 1998 GMC, 960 N.E.2d 1071 (Ill. 2011). “¶ 1 The issue presented in this case is whether the vehicle-forfeiture provisions of the Criminal Code of 1961 (the Criminal Code) (720 ILCS 5/36-1 through 36-4 (West 2006)) are facially unconstitutional as a violation of procedural due process because they do not include a…”
People v. ex rel. Hartrich v. 2010 Harley-Davidson, 2016 IL App (5th) 150035 (Ill. App. Ct. 2016). “720 ILCS 5/36-1(a) (West 2014). Pertinent for our purposes, a vehicle is subject to forfeiture if it is used to commit the offense of DUI during a period of time in which the driver's license has been revoked or suspended due to a prior DUI.”
Wirtz v. Quinn, 2011 IL 111903 (Ill. 2011). “1 (West 1994)), a provision in the Criminal Code of 1961 dealing with the seizure and forfeiture of vehicles ( 720 ILCS 5/36-1 (West 1994)), and a provision in the Unified Code of Corrections concerning reimbursement of expenses by convicted persons to the Department of…”
People v. ex re. Nerheim v. 2005 Black Chevrolet Corvette, 2015 IL App (2d) 131267 (Ill. App. Ct. 2015). “BACKGROUND ¶3 On April 9, 2013, the State filed a complaint for seizure and forfeiture of defendant’s 2005 Corvette, under section 36-1 of the Criminal Code of 2012 (Code) (720 ILCS 5/36-1 (West 2012)). The complaint alleged that the vehicle was used in defendant’s commission of…”
Wirtz v. Quinn, 953 N.E.2d 899 (Ill. 2011). “1 (West 1994)), a provision in the Criminal Code of 1961 dealing with the seizure and forfeiture of vehicles (720 ILCS 5/36-1 (West 1994)), and a provision in the Unified Code of Corrections concerning reimbursement of expenses by convicted persons to the Department of…”
People v. One 2005 Acura RSX, 2017 IL App (4th) 160595 (Ill. App. Ct. 2017). “The State filed the complaint pursuant to section 36-1 of the Criminal Code of 2012 (Criminal Code) (720 ILCS 5/36-1 (West 2014)). ¶2 Following a hearing, the trial court found forfeiture of the vehicle would violate the excessive fines clause of the eighth amendment to the…”
People v. ex rel. Hartrich v. 2010 Harley-Davidson, 2016 IL App (5th) 150035 (Ill. App. Ct. 2016). “720 ILCS 5/36-1(a) (West 2014). Pertinent for our purposes, a vehicle is subject to forfeiture if it is used to commit the offense of DUI during a period of time in which the driver’s license has been revoked or suspended due to a prior DUI.”
People v. Heritsch, 2012 IL App (2d) 90719 (Ill. App. Ct. 2012). “Section 6-303(g) of the Code provides: “The motor vehicle used in a violation of this Section is subject to seizure and forfeiture as provided in Sections 36-1 and 36-2 of the Criminal Code of 1961 if the person’s driving privilege was revoked or suspended as a result of a…”
Thompson v. Vill. of Monee, 110 F. Supp. 3d 826 (N.D. Ill. 2015). “” See 720 ILCS 5/36-1(a). The specified offenses which range from first degree murder and armed robbery to driving under the influence without a valid driver’s license (see 720 ILCS 5/36—1 (a)(1)—(8)) and include “Section 11-204.”
— 720 ILCS 5/36-1(a) — 5 cases
People v. ex rel. Hartrich v. 2010 Harley-Davidson, 2016 IL App (5th) 150035 (Ill. App. Ct. 2016). “720 ILCS 5/36-1(a) (West 2014). Pertinent for our purposes, a vehicle is subject to forfeiture if it is used to commit the offense of DUI during a period of time in which the driver's license has been revoked or suspended due to a prior DUI.”
People v. ex rel. Hartrich v. 2010 Harley-Davidson, 2016 IL App (5th) 150035 (Ill. App. Ct. 2016). “720 ILCS 5/36-1(a) (West 2014). Pertinent for our purposes, a vehicle is subject to forfeiture if it is used to commit the offense of DUI during a period of time in which the driver’s license has been revoked or suspended due to a prior DUI.”
Thompson v. Vill. of Monee, 110 F. Supp. 3d 826 (N.D. Ill. 2015). “” See 720 ILCS 5/36-1(a). The specified offenses which range from first degree murder and armed robbery to driving under the influence without a valid driver’s license (see 720 ILCS 5/36—1 (a)(1)—(8)) and include “Section 11-204.”
People ex rel. Kelly v. One 2008 Chevrolet Trailblazer, 2016 IL App (5th) 150338 (Ill. App. Ct. 2016).
People ex rel. Kelly v. One 2008 Chevrolet Trailblazer, 2016 IL App (5th) 150338 (Ill. App. Ct. 2016).
— 720 ILCS 5/36-1(a)(5) — 1 case
Thompson v. Vill. of Monee, 110 F. Supp. 3d 826 (N.D. Ill. 2015). “” See 720 ILCS 5/36-1(a). The specified offenses which range from first degree murder and armed robbery to driving under the influence without a valid driver’s license (see 720 ILCS 5/36—1 (a)(1)—(8)) and include “Section 11-204.”
— 720 ILCS 5/36-1(a)(6)(A) — 1 case
People ex rel. Hartrich v. 2010 Harley-Davidson, 2018 IL 121636 (Ill. 2018). “Those facts showed that her husband was driving on a revoked license while under the influence of alcohol after an earlier revocation was extended due to his prior conviction for driving while his license was revoked, following multiple driving under the influence (DUI)…”
— 720 ILCS 5/36-1(a)(6)(A)(i) — 4 cases
People ex rel. Hartrich v. 2010 Harley-Davidson, 2018 IL 121636 (Ill. 2018). “Those facts showed that her husband was driving on a revoked license while under the influence of alcohol after an earlier revocation was extended due to his prior conviction for driving while his license was revoked, following multiple driving under the influence (DUI)…”
People ex rel. Hartrich v. 2010 Harley-Davidson, 2018 IL 121636 (Ill. 2018). “¶2 After the trial court ordered the forfeiture of the claimant’s motorcycle based on her husband’s criminal conduct while driving it, she first raised an as-applied constitutional challenge to the Illinois civil forfeiture statute (720 ILCS 5/36-1 (West 2012)). She argued that…”
People v. ex rel. Hartrich v. 2010 Harley-Davidson, 2016 IL App (5th) 150035 (Ill. App. Ct. 2016). “720 ILCS 5/36-1(a) (West 2014). Pertinent for our purposes, a vehicle is subject to forfeiture if it is used to commit the offense of DUI during a period of time in which the driver's license has been revoked or suspended due to a prior DUI.”
People v. ex rel. Hartrich v. 2010 Harley-Davidson, 2016 IL App (5th) 150035 (Ill. App. Ct. 2016). “720 ILCS 5/36-1(a) (West 2014). Pertinent for our purposes, a vehicle is subject to forfeiture if it is used to commit the offense of DUI during a period of time in which the driver’s license has been revoked or suspended due to a prior DUI.”
— 720 ILCS 5/36-1(a)(6)(C) — 1 case
People v. 2017 Ford Explorer, 2022 IL App (3d) 210368 (Ill. App. Ct. 2022).
— 720 ILCS 5/36-1(d) — 2 cases
People ex rel. Hartrich v. 2010 Harley-Davidson, 2018 IL 121636 (Ill. 2018). “Those facts showed that her husband was driving on a revoked license while under the influence of alcohol after an earlier revocation was extended due to his prior conviction for driving while his license was revoked, following multiple driving under the influence (DUI)…”
People ex rel. Hartrich v. 2010 Harley-Davidson, 2018 IL 121636 (Ill. 2018). “¶2 After the trial court ordered the forfeiture of the claimant’s motorcycle based on her husband’s criminal conduct while driving it, she first raised an as-applied constitutional challenge to the Illinois civil forfeiture statute (720 ILCS 5/36-1 (West 2012)). She argued that…”
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