Adult Juvenile-Age Convictions Qualify as Predicate Offenses Under the Illinois Armed Habitual Criminal Statute

Introduction

People v. Wallace, 2025 IL 130173, is a landmark decision in which the Illinois Supreme Court resolved a novel question of statutory interpretation concerning the interplay between the Juvenile Court Act and the armed habitual criminal statute. The defendant, Deshawn Wallace, convicted in 2019 for being an armed habitual criminal, challenged the use of a 2008 armed robbery conviction—entered against him when he was 17—as a “predicate felony conviction.” Wallace argued that under the amended Juvenile Court Act (which in 2014 raised the age of juvenile jurisdiction from under 17 to under 18), his 2008 offense would today be adjudicated in juvenile court and thus could not serve as an adult felony conviction. The Illinois Supreme Court unanimously rejected that argument, affirming that convictions rendered in criminal court at the time they were entered qualify as predicate convictions under the armed habitual criminal statute—even if, under current law, the offender might now be eligible for juvenile adjudication.

Summary of the Judgment

The Supreme Court of Illinois affirmed the First District appellate court and the Cook County trial court. It held, by a majority opinion delivered by Justice Cunningham, that:

The armed habitual criminal statute (720 ILCS 5/24-1.7(a) (West 2018)) requires proof only that the defendant has two or more qualifying prior convictions as they were entered at the time.
The plain statutory language does not incorporate the present-day age of the offender or the Juvenile Court Act’s discretionary transfer provisions into the definition of “predicate convictions.”
Because Wallace’s 2008 armed robbery conviction was entered against him in adult criminal court—and was thus a valid “forcible felony” conviction—it properly served as a predicate offense for the armed habitual criminal charge in 2019.

Accordingly, the judgment of the appellate court was affirmed.

Analysis

1. Precedents Cited

The Court relied on fundamental principles of statutory interpretation and several key decisions:

People v. Sroga, 2022 IL 126978: Reaffirmed that courts must give effect to the plain language of a statute and may not read in unstated exceptions or conditions.
Lynch v. Alworth-Stephens Co., 267 U.S. 364 (1925): Emphasized that hidden or strained constructions at odds with express statutory text are to be avoided.
People v. Stewart, 2022 IL 126116: Addressed whether a juvenile-aged burglary conviction qualified for Class X sentencing, distinguishing it by reference to a subsequent legislative amendment that explicitly barred under-21 convictions.
Appellate decisions Irrelevant, Hawkins, and Brown (1st & 4th Dist. 2021–2024): Rejected incorporation of the Juvenile Court Act’s present-day transfer scheme into the armed habitual criminal predicate analysis.

2. Legal Reasoning

The Court began with the armed habitual criminal statute’s plain text: a defendant must have been “convicted a total of 2 or more times” of specified predicate offenses, including “a forcible felony as defined in Section 2-8” of the Criminal Code. Wallace’s 2008 armed robbery conviction met that definition, and his 2015 unlawful use of a weapon by a felon conviction satisfied the second predicate. The statute’s use of present-tense phrases—such as offenses “as defined,” “as described,” or “punishable as”—simply directs the court to consult the definitions and punishments in force when the habitual criminal charge is tried.

Wallace urged a different interpretation, contending that the present-tense language imports the current juvenile adjudication rules, thus requiring a “mini-trial” to determine whether a 17-year-old offender today would have been tried as an adult. The Court rejected this, finding no textual support for importing the Juvenile Court Act’s eligibility criteria or transfer factors. Absent an explicit legislative directive, courts must honor the statutory text as written and not graft on complex scheme-wide provisions inimical to the statute’s streamlined predicate-conviction focus.

Distinguishing Stewart, the Court noted that in the Class X sentencing context the legislature had since amended the statute to impose an express age requirement for qualifying offenses—demonstrating that when the legislature intends to disqualify convictions based on the offender’s age at the time, it knows how to say so. No such amendment exists in the armed habitual criminal statute.

3. Impact

This decision clarifies that:

Convictions entered in adult criminal court at the time of sentencing remain valid predicate convictions, even if, under subsequent legislative changes, the defendant would have been eligible for juvenile adjudication.
Counsel defending armed habitual criminal charges cannot challenge predicate felonies on the basis of post-conviction amendments to the Juvenile Court Act or other statutes.
The legislature, if it wishes to alter this framework, must expressly amend the armed habitual criminal statute to exclude adult convictions of juvenile-age offenders or to incorporate juvenile transfer criteria.

Complex Concepts Simplified

Forcible Felony: An offense that involves the use or threat of physical force, such as robbery or aggravated battery, as defined in Section 2-8 of the Criminal Code.
Predicate Conviction: A prior conviction that the statute expressly lists—here, forcible felonies or weapons offenses—used to establish habitual offender status.
Juvenile Adjudication vs. Adult Conviction: Under the Juvenile Court Act, certain offenses committed by minors are handled in juvenile court rather than criminal court. An adult conviction occurs when a minor is tried as an adult and receives a standard criminal sentence.
Discretionary Transfer: A juvenile court procedure by which a 17-year-old may be transferred to adult criminal court if factors like past delinquency history or offense severity warrant harsher adjudication.

Conclusion

People v. Wallace establishes that the armed habitual criminal statute looks to the existence of prior adult convictions as entered at the time, not to hypothetical present-day juvenile-court outcomes. The decision reinforces the primacy of plain statutory language, eschewing strained constructions that would import external legislative schemes without clear textual mandate. Going forward, prosecutors can rely on valid adult convictions—regardless of the defendant’s age when committed—as predicate felonies under the armed habitual criminal law, unless and until the General Assembly chooses to enact an express age-based limitation.