People v. Gray
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In this case, defendant Demetrius Gray was convicted of the offense of being an armed habitual criminal. The appellate court reversed this conviction, contending that the prosecution failed to prove that Gray had two prior qualifying felony convictions because he was 17 years old at the time of one of the alleged predicate offenses. The State appealed this decision, arguing that the evidence at trial was sufficient to prove the elements necessary to convict Gray of being an armed habitual criminal.
The Supreme Court of the State of Illinois reversed the appellate court's judgment and affirmed Gray's conviction. The court found that Gray's defense counsel's stipulation that Gray had "two prior qualifying felony convictions for the purposes of sustaining the charge of armed habitual criminal" was sufficient evidence of Gray's prior qualifying convictions. Therefore, the State did not need to present further evidence in support of the stipulated fact of Gray's prior qualifying offenses. The court also rejected Gray's claim of ineffective assistance of counsel in making the stipulation as Gray could not show that, but for the deficiency in counsel's representation, there is a reasonable probability the trial result would have been different. The court concluded that a rational trier of fact could have found the essential elements of the charge of being an armed habitual criminal beyond a reasonable doubt.
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