People v. Roberson, 212 Ill. 2d 430

Summary

The Supreme Court of Illinois held that a defendant convicted of violating a bail bond was entitled to sentencing credit under section 5-8-7(b) of the Unified Code of Corrections for time spent in custody following his arrest on the bail-related offense. The court rejected the lower courts' reasoning that credit was unavailable because the defendant was not formally charged with the bail-bond violation until later. Although the appeal was moot because the defendant had completed his sentence and mandatory supervised release, the court reached the merits under the public-interest exception to mootness.

Holdings

1. Although the appeal was moot because Roberson had completed his sentence and mandatory supervised release, the court reached the merits under the public-interest exception because the issue was of a public nature, was likely to recur, and required authoritative guidance for public officers.
2. A defendant is entitled under section 5-8-7(b) to credit for time spent in custody resulting from the bail-bond offense when the defendant was arrested for that offense, detained, and ultimately convicted and sentenced for it, even if formal charging occurred later.
3. The court did not reach the parties' arguments concerning section 5-8-7(c) because its conclusion that section 5-8-7(b) controlled was dispositive.

Questions Presented

1. Whether the appeal should be dismissed as moot because Roberson had completed his sentence and mandatory supervised release.
2. Whether the public-interest exception permitted review of the otherwise moot sentencing-credit issue.
3. Whether time spent in custody following Roberson's second arrest was attributable to the bail-bond offense and therefore required to be credited under section 5-8-7(b) of the Unified Code of Corrections.
4. Whether the court needed to decide whether section 5-8-7(c) independently required the requested credit.

Disposition

reversed