People v. Jenkins

Appellate Court of Illinois·Decided July 21, 2026·No. 3-25-0306·Published

Opinion

2026 IL App (3d) 250306

Opinion filed July 21, 2026 ____________________________________________________________________________

IN THE

APPELLATE COURT OF ILLINOIS

THIRD DISTRICT

THE PEOPLE OF THE STATE OF ) Appeal from the Circuit Court ILLINOIS, ) of the 18th Judicial Circuit, ) Du Page County, Illinois. Plaintiff-Appellee, ) ) Appeal No. 3-25-0306 v. ) Circuit No. 19-CM-1118 ) DESIREE C. JENKINS, ) Honorable ) Robert A. Miller, Defendant-Appellant. ) Judge, Presiding. ____________________________________________________________________________

PRESIDING JUSTICE HETTEL delivered the judgment of the court, with opinion. Justices Brennan and Peterson concurred in the judgment and opinion. ____________________________________________________________________________

OPINION

¶1 Defendant, Desiree C. Jenkins, appeals from the Du Page County circuit court’s denial of

her petition to expunge her criminal record. Defendant argues that the court erred by applying the

incorrect waiting period to her eligibility to apply for expungement and abused its discretion in

denying her unopposed petition and motion to reconsider. We affirm.

¶2 I. BACKGROUND

¶3 On May 29, 2019, defendant was charged with retail theft (720 ILCS 5/16-25(a)(1) (West

2018)). On June 3, 2021, defendant pled guilty and was sentenced to one year of court

supervision. Defendant was satisfactorily terminated from court supervision on June 2, 2022. On January 31, 2025, defendant filed a pro se petition to expunge her criminal record. She indicated

that she was not requesting to seal her records. The state’s attorney’s office filed a response

indicating that it had no objection.

¶4 After a hearing on April 25, 2025, the court denied defendant’s petition, explaining that

pursuant to section 5-6-3.1(f) of the Unified Code of Corrections (Code) (730 ILCS 5/5-6-3.1(f)

(West 2024)), defendant was ineligible to seek expungement of her retail theft record until five

years had elapsed after the termination of her court supervision. The court elaborated that the

five-year time limit applied to her offense because the statute enabled a person to receive a

sentence of court supervision only once in a five-year period. On May 9, 2025, defendant filed a

motion to reconsider arguing that retail theft fell into the “catch-all” provision of section

5.2(b)(2)(B)(ii) of the Criminal Identification Act (Act) (20 ILCS 2630/5.2(b)(2)(B)(ii) (West

2024)), which made her eligible for expungement two years after the termination of her court

supervision. In denying the motion to reconsider, the court reiterated that the five-year time limit

for retail theft was directly tied to two separate sentencing statutes and if defendant were able to

expunge her record after two years, “then [she] could possibly get court supervision again after

three which would defeat both purposes.” Defendant appealed.

¶5 II. ANALYSIS

¶6 On appeal, defendant argues that the court (1) erred in applying the incorrect statute when

denying her petition to expunge, (2) abused its discretion by denying the petition, despite the

lack of objections from the State and law enforcement agencies, and (3) abused its discretion by

denying her motion to reconsider. We consider each argument in turn.

¶7 Defendant argues first that the court incorrectly applied the five-year waiting period

prescribed by section 5-6-3.1 of the Code instead of the correct two-year waiting period provided

2 by section 5.2 of the Act. Deciding which statute applies is a matter of statutory interpretation.

“The primary objective of statutory construction is to ascertain and give effect to the intent of the

legislature. The most reliable indicator of legislative intent is the language of the statute, given

its plain and ordinary meaning.” People v. Jackson, 2011 IL 110615, ¶ 12. When determining the

plain meaning of a statute, a reviewing court will consider the statute in its entirety and bear in

mind the subject that the statute addresses and the apparent intent of the legislature in enacting

the statute. People v. Haberkorn, 2018 IL App (3d) 160599, ¶ 26. “No part of a statute should be

rendered meaningless or superfluous.” Van Dyke v. White, 2019 IL 121452, ¶ 46.

¶8 Both sections address the time frame that a person placed on court supervision must wait

to attempt to have their charge expunged. Section 5.2(b)(2)(B) of the Act states:

(B) When the arrest or charge *** sought to be expunged resulted in an

order of supervision, successfully completed by the petitioner, the following time

frames will apply:

(i) Those arrests or charges that resulted in orders of supervision

under Section 3-707, 3-708, 3-710, or 5-401.3 of the Illinois Vehicle Code

***, or under Section 11-1.50, 12-3.2, or 12-15 of the *** Criminal Code

of 2012, *** shall not be eligible for expungement until 5 years have

passed following the satisfactory termination of the supervision.

***

(ii) Those arrests or charges that resulted in orders of supervision

for any other offenses shall not be eligible for expungement until 2 years

have passed following the satisfactory termination of the supervision.” 20

ILCS 2630/5.2(b)(2)(B)(i), (ii) (West 2024).

3 Retail theft is not specifically enumerated in the Act.

¶9 Section 5-6-3.1 of the Code specifically includes more violations that are subject to a

five-year restriction, including retail theft. This section provides that individuals who are placed

on supervision are eligible to have their record sealed or expunged after two years,

“unless the disposition of supervision was for a violation of Sections 3-707, 3-708, 3-710,

5-401.3, or 11-503 of the Illinois Vehicle Code *** or for a violation of Sections 12-3.2,

16-25, or 16A-3 of the *** Criminal Code of 2012, in which case it shall be 5 years after

discharge.” 730 ILCS 5/5-6-3.1(f) (West 2024).

Where two statutes apply to the same cause of action, here, the time frame for expungement

eligibility, the statute that more specifically relates to that action must be applied. Watseka First

National Bank v. Horney, 292 Ill. App. 3d 933, 937 (1997).

¶ 10 Section 5-6-3.1 makes specific reference to the retail theft statute (section 16-25 of the

Criminal Code of 2012). Additionally, the Code contains another provision that explains the

necessity for the five-year time limit for expungement. Section 5-6-1 of the Code states that a

person charged with retail theft is ineligible for court supervision if, within the last five years, the

person was previously assigned supervision for retail theft. 730 ILCS 5/5-6-1(e)(2) (West 2024).

Applying the general two-year time limit contained within the Act would lead to absurd results

that defy the clear legislative intent and render two statutory provisions superfluous. See

Jackson, 2011 IL 110615, ¶ 12. Accordingly, the court applied the correct statutory time limit to

defendant’s petition to expunge.

¶ 11 Next, defendant contends that the court abused its discretion in denying her petition to

expunge where the state’s attorney’s office did not object to the expungement. Courts possess

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