{ "id": 45748, "name": "THE PEOPLE OF THE STATE OF ILLINOIS, Plaintiff-Appellee, v. GARY REEDY, Defendant-Appellant", "name_abbreviation": "People v. Reedy", "decision_date": "1998-03-11", "docket_number": "No. 2\u201496\u20140101", "first_page": "34", "last_page": "44", "citations": [ { "type": "official", "cite": "295 Ill. App. 3d 34" } ], "court": { "name_abbreviation": "Ill. App. Ct.", "id": 8837, "name": "Illinois Appellate Court" }, "jurisdiction": { "id": 29, "name_long": "Illinois", "name": "Ill." }, "cites_to": [ { "cite": "134 Ill. App. 3d 352", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 3637595 ], "weight": 2, "year": 1985, "pin_cites": [ { "page": "358" }, { "page": "358" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/134/0352-01" ] }, { "cite": "61 Ill. 2d 277", "category": "reporters:state", "reporter": "Ill. 2d", "case_ids": [ 2966304 ], "weight": 2, "year": 1975, "pin_cites": [ { "page": "278, 283-84" }, { "page": "278, 283-84" } ], "opinion_index": 0, "case_paths": [ "/ill-2d/61/0277-01" ] }, { "cite": "116 Ill. 2d 186", "category": "reporters:state", "reporter": "Ill. 2d", "case_ids": [ 5543542 ], "year": 1987, "pin_cites": [ { "page": "214" } ], "opinion_index": 0, "case_paths": [ "/ill-2d/116/0186-01" ] }, { "cite": "176 Ill. 2d 414", "category": "reporters:state", "reporter": "Ill. 2d", "case_ids": [ 544894 ], "year": 1997, "pin_cites": [ { "page": "422" } ], "opinion_index": 0, "case_paths": [ "/ill-2d/176/0414-01" ] }, { "cite": "165 Ill. 2d 235", "category": "reporters:state", "reporter": "Ill. 2d", "case_ids": [ 483556 ], "weight": 2, "year": 1995, "pin_cites": [ { "page": "255" }, { "page": "255" } ], "opinion_index": 0, "case_paths": [ "/ill-2d/165/0235-01" ] }, { "cite": "42 Minn. L. Rev. 389", "category": "journals:journal", "reporter": "Minn. L. Rev.", "year": 1958, "pin_cites": [ { "page": "391" } ], "opinion_index": 0 }, { "cite": "13 Mich. 481", "category": "reporters:state", "reporter": "Mich.", "case_ids": [ 1949681 ], "year": 1865, "pin_cites": [ { "page": "494-95" } ], "opinion_index": 0, "case_paths": [ "/mich/13/0481-01" ] }, { "cite": "57 Ill. 2d 193", "category": "reporters:state", "reporter": "Ill. 2d", "case_ids": [ 5406336 ], "year": 1974, "pin_cites": [ { "page": "202" } ], "opinion_index": 0, "case_paths": [ "/ill-2d/57/0193-01" ] }, { "cite": "153 Ill. 2d 239", "category": "reporters:state", "reporter": "Ill. 2d", "case_ids": [ 4739021 ], "weight": 2, "year": 1992, "pin_cites": [ { "page": "258" }, { "page": "257-58" } ], "opinion_index": 0, "case_paths": [ "/ill-2d/153/0239-01" ] }, { "cite": "176 Ill. 2d 499", "category": "reporters:state", "reporter": "Ill. 2d", "case_ids": [ 544904 ], "weight": 11, "year": 1997, "pin_cites": [ { "page": "502" }, { "page": "503" }, { "page": "514" }, { "page": "514" }, { "page": "514" }, { "page": "514-15" }, { "page": "515" }, { "page": "515" }, { "page": "515" }, { "page": "515-16" }, { "page": "512" } ], "opinion_index": 0, "case_paths": [ "/ill-2d/176/0499-01" ] }, { "cite": "180 Ill. App. 3d 726", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 2612890 ], "year": 1989, "pin_cites": [ { "page": "733" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/180/0726-01" ] }, { "cite": "132 Ill. App. 3d 384", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 3441383 ], "year": 1985, "pin_cites": [ { "page": "389" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/132/0384-01" ] }, { "cite": "227 Ill. App. 3d 1003", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 5795887 ], "year": 1992, "pin_cites": [ { "page": "1009" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/227/1003-01" ] }, { "cite": "284 Ill. App. 3d 382", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 1260334 ], "year": 1996, "pin_cites": [ { "page": "387", "parenthetical": "\"compliance with conditions for awarding good-time credit is one of the terms of the original sentence\"" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/284/0382-01" ] }, { "cite": "31 Ill. 2d 354", "category": "reporters:state", "reporter": "Ill. 2d", "case_ids": [ 2834879 ], "year": 1964, "pin_cites": [ { "page": "357", "parenthetical": "good time is \"a part of every sentence\"" } ], "opinion_index": 0, "case_paths": [ "/ill-2d/31/0354-01" ] }, { "cite": "294 Ill. App. 3d 462", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 35380 ], "weight": 6, "year": 1997, "pin_cites": [ { "page": "464" }, { "page": "463-64" }, { "page": "464" }, { "page": "464" }, { "page": "463-64" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/294/0462-01" ] }, { "cite": "111 Const. 1970", "category": "reporters:state", "reporter": "Mill", "opinion_index": 0 } ], "analysis": { "cardinality": 951, "char_count": 23047, "ocr_confidence": 0.78, "pagerank": { "raw": 2.936325585466015e-07, "percentile": 0.8477527068180423 }, "sha256": "bd4d3ce2a155d231c239dad8a9427eb7819efd5c6023e13afeefdcc160a932c1", "simhash": "1:8a7643a82f6edffc", "word_count": 3778 }, "last_updated": "2023-07-14T18:51:11.490834+00:00", "provenance": { "date_added": "2019-08-29", "source": "Harvard", "batch": "2018" }, "casebody": { "judges": [], "parties": [ "THE PEOPLE OF THE STATE OF ILLINOIS, Plaintiff-Appellee, v. GARY REEDY, Defendant-Appellant." ], "opinions": [ { "text": "JUSTICE McLAREN\ndelivered the opinion of the court:\nDefendant, Gary Reedy, was convicted by a jury of aggravated battery with a firearm (720 ILCS 5/12 \u2014 4.2(a)(1) (West 1996)) and was sentenced to 15 years in prison. Under the \u201ctruth-in-sentencing\u201d provisions of section 3 \u2014 6\u20143(a)(2)(ii) of the Unified Code of Corrections, defendant is eligible to receive no more than 4.5 days of good conduct credit for each month of his sentence. 730 ILCS 5/3 \u2014 6\u2014 3(a)(2)(ii) (West 1996).\nOn appeal, defendant argues that the truth-in-sentencing provisions of section 3 \u2014 6\u20143(a)(2)(ii) are unconstitutional and therefore unenforceable. In support, defendant first contends that Public Act 89 \u2014 404 (Pub. Act 89 \u2014 404, eff. August 20, 1995), in which the legislature enacted section 3 \u2014 6\u20143(a)(2)(h), violates the single subject rule of the Illinois Constitution of 1970 (111. Const. 1970, art. IV, \u00a7 8(d)). Defendant also argues that section 3 \u2014 6\u20143(a)(2)(h) violates the equal protection clause (U.S. Const., amend. XTV, \u00a7 1; 111 Const. 1970, art. I, \u00a7 2) by treating similarly situated offenders in a dissimilar manner. In response, the State first contends that defendant may not challenge section 3 \u2014 6\u20143(a)(2)(ii)\u2019s constitutionality on direct appeal. Alternatively, the State argues that section 3 \u2014 6\u20143(a)(2)(h) is constitutional. For the reasons set forth below, we agree with defendant that the legislature enacted section 3 \u2014 6\u20143(a)(2)(h) in violation of the single subject rule.\nI. DIRECT APPEAL\nThe State initially argues that defendant may not challenge section 3 \u2014 6\u20143(a)(2)(ii)\u2019s constitutionality on direct appeal. In support, the State cites the opinion in People v. Watford, 294 Ill. App. 3d 462 (1997), of the Appellate Court, Third District.\nIn Watford, the defendant raised the same issue that defendant raises in this appeal, namely, whether section 3 \u2014 6\u20143(a)(2)(ii)\u2019s truth-in-sentencing provisions are constitutional. The court concluded, without any citation to authority, that a defendant subject to truth-in-sentencing legislation cannot challenge the constitutionality of that legislation on direct appeal. Watford, 294 Ill. App. 3d at 464. Watford explained that, because the responsibility for enforcing the truth-in-sentencing laws lies with the Department of Corrections and not with the trial court, those laws are \u201cnot intended to be a condition of the defendant\u2019s sentence,\u201d have \u201cno legal effect on the sentencing proceeding,\u201d and are \u201ca matter outside the scope of the sentencing proceedings.\u201d Watford, 294 Ill. App. 3d at 463-64. Consequently, to challenge the constitutionality of the truth-in-sentencing laws, a defendant first must wait for the Department of Corrections to calculate his good-time credit. Watford, 294 Ill. App. 3d at 464. The defendant then may file a habeas corpus, mandamus, or declaratory judgment action alleging that the Department of Corrections is calculating his credit improperly. Watford, 294 Ill. App. 3d at 464.\nWe are not persuaded by Watford. In Illinois, a criminal defendant possesses the right to appeal directly from any sentence imposed for a felony conviction. 730 ILCS 5/5 \u2014 5\u20144.1 (West 1996). Illinois courts have long recognized that good-time credit is a part of every sentence. See, e.g., People ex rel. Colletti v. Pate, 31 Ill. 2d 354, 357 (1964) (good time is \u201ca part of every sentence\u201d); People v. Baptist, 284 Ill. App. 3d 382, 387 (1996) (\u201ccompliance with conditions for awarding good-time credit is one of the terms of the original sentence\u201d). Indeed, this court has held on numerous occasions that, because good-time credit is \u201c \u2018inherent in every sentence of imprisonment,\u2019 \u201d a sentencing court may consider the possibility of good-time credit when fashioning a defendant\u2019s sentence. See People v. Fetter, 227 Ill. App. 3d 1003, 1009 (1992), quoting People v. Torgeson, 132 Ill. App. 3d 384, 389 (1985); People v. Clankie, 180 Ill. App. 3d 726, 733 (1989). If the nexus between good-time credit and the defendant\u2019s sentence allows the trial court to factor in the former when imposing the latter, it likewise allows a defendant to question the validity of the former on direct appeal of the latter.\nMoreover, even if good-time credit were not \u201cinherent in every sentence of imprisonment\u201d as a general matter, it is inherent in every sentence subject to the truth-in-sentencing laws'. Section 5 \u2014 4\u2014 l(c \u2014 2) of the Unified Code of Corrections compels the trial court at the defendant\u2019s sentencing hearing to (1) inform the public that the defendant is subject to section 3 \u2014 6\u20143(a)(2)(ii)\u2019s truth-in-sentencing provisions, and (2) based upon the application of those provisions, advise the public of \u201cthe actual period of time this defendant is likely to spend in prison as a result of this sentence.\u201d (Emphasis added.) 730 ILCS 5/5 \u2014 4\u2014l(c\u20142) (West 1996). Significantly, section 5 \u2014 4\u2014l(c\u20142) is itself part of the truth-in-sentencing legislation enacted by Public Act 89 \u2014 404. Thus, by its own terms, the truth-in-sentencing act injects itself into a defendant\u2019s sentencing hearing. We therefore cannot agree with Watford\u2019s conclusion that the truth-in-sentencing act has \u201cno legal effect on the sentencing proceeding\u201d and is \u201ca matter outside the scope of the sentencing proceedings.\u201d Watford, 294 Ill. App. 3d at 463-64.\nAccordingly, contrary to Watford, we hold that a defendant subject to section 3 \u2014 6\u20143(a)(2)(ii)\u2019s truth-in-sentencing provisions may challenge the constitutionality of those provisions on direct appeal. We therefore proceed to the merits of defendant\u2019s appeal.\nII. THE SINGLE SUBJECT RULE\nWe next address defendant\u2019s contention that section 3 \u2014 6\u2014 3(a)(2)(ii) is unconstitutional because it was enacted in violation of the single subject rule of the Illinois Constitution of 1970 (111. Const. 1970, art. IV, \u00a7 8(d)).\nA. BACKGROUND\nSection 3 \u2014 6\u20143(a)(2)(ii), in its current form, was enacted on August 20, 1995, as part of Public Act 89 \u2014 404. Prior to Public Act 89 \u2014 404\u2019s enactment, a person convicted of aggravated battery with a firearm was eligible to receive one day of good conduct credit for each day of service in prison. See 730 ILCS 5/3 \u2014 6\u20143(a)(2) (West 1994). Effective August 20, 1995, Public Act 89 \u2014 404 amended section 3 \u2014 6\u20143(a)(2) to state that a person convicted of aggravated battery with a firearm is eligible to receive only 4.5 days of good conduct credit for each month of his sentence. In this case, the trial court sentenced defendant under the amended version of section 3 \u2014 6\u2014 3(a)(2) (730 ILCS 5/3 \u2014 6\u20143(a)(2)(ii) (West 1996)).\nDefendant\u2019s primary argument in this appeal is that Public Act 89 \u2014 404 violates the single subject rule of the Illinois Constitution. The single subject rule governs the method by which legislation is enacted. Johnson v. Edgar, 176 Ill. 2d 499, 502 (1997). Therefore, before analyzing whether Public Act 89 \u2014 404 complies with the single subject rule, we will examine both the procedural history and the substance of that act. See Johnson, 176 Ill. 2d at 503.\n1. Procedural History\nPublic Act 89 \u2014 404 began its life on March 3, 1995, as Senate Bill 1187. Entitled \u201cA Bill for an Act concerning the insanity defense,\u201d Senate Bill 1187 originally (1) increased the burden of proof for a defendant asserting the insanity defense, (2) redefined the term \u201cinsanity,\u201d and (3) revised the procedures governing petitions for the transfer or release of defendants found not guilty by reason of insanity. On April 25, 1995, the Senate passed the bill without amendment.\nWhen it reached the House of Representatives, Senate Bill 1187 experienced considerable growth through a series of amendments. In one of its amendments, the House deleted the bill\u2019s entire text and started from scratch. No longer confined to the insanity defense, Senate Bill 1187 now also addressed such topics as (1) the duties and jurisdiction of local law enforcement officials, (2) asset forfeiture proceedings arising from drug offenses, (3) truth-in-sentencing, and (4) the perfection and attachment of hospital liens. Recognizing that the bill\u2019s original title no longer was accurate, the House renamed Senate Bill 1187 \u201cAn Act in relation to governmental matters, amending named Acts.\u201d The House passed Senate Bill 1187 with these amendments and sent it back to the Senate.\nOn May 24, 1995, the Senate considered and debated Senate Bill 1187 in its amended form. Unlike the debate that preceded the Senate\u2019s April 25, 1995, vote, this debate did not in any way address the bill\u2019s insanity defense provisions. Instead, the debate was confined solely to the bill\u2019s truth-in-sentencing provisions. At the close of the debate, the Senate voted on and passed Senate Bill 1187 as amended by the House.\nOn June 22, 1995, Senate Bill 1187 was sent to Governor Edgar for signature. On August 20, 1995, Governor Edgar approved the bill and signed it into law as Public Act 89 \u2014 404.\n2. Substantive Provisions\nIn its enacted form, Public Act 89 \u2014 404 contains 10 sections covering an impressive array of subjects. Section 5 amends the Counties Code (55 ILCS 5/1 \u2014 1001 et seq. (West 1994)) to redefine the sheriff\u2019s duties as \u201cconservator of the peace.\u201d Similarly, section 10 amends the Illinois Municipal Code (65 ILCS 5/1 \u2014 1\u20141 et seq. (West 1996)) to redefine the local police department\u2019s duties as \u201cpeace officers.\u201d\nSection 15 amends the Criminal Code of 1961 (720 ILCS 5/1 \u2014 1 et seq. (West 1996)) to (1) increase the burden of proof for a defendant asserting the insanity defense and (2) redefine the term \u201cinsanity.\u201d\nSection 20 amends the Cannabis Control Act (720 ILCS 550/1 et seq. (West 1996)) to provide for a new distribution of the proceeds from an asset forfeiture sale conducted pursuant to that act.\nSection 25 amends the Illinois Controlled Substances Act (720 ILCS 570/100 et seq. (West 1996)) to (1) allow multiple convictions and sentences for persons who violate that act with respect to more than one type of controlled substance, (2) define each violation of that act as a separate offense, (3) impose sentencing guidelines for persons convicted of violating that act, and (4) provide for a new distribution of the proceeds from an asset forfeiture sale conducted pursuant to that act.\nSection 30 amends the Code of Criminal Procedure of 1963 (725 ILCS 5/100 \u2014 1 et seq. (West 1996)) to (1) define the term \u201claw enforcement agency\u201d and (2) expand a police officer\u2019s power to make arrests outside of his or her jurisdiction.\nSection 35 amends the Drug Assets Forfeiture Procedure Act (725 ILCS 150/1 et seq. (West 1996)) by deleting the requirement that judicial in rem proceedings be held by the court and without a jury.\nSection 40 amends the Unified Code of Corrections (730 ILCS 5/1 \u2014 1\u20141 et seq. (West 1996)) to (1) revise the rules and regulations governing good conduct credit and early release, (2) create the Illinois Truth-in-Sentencing Commission, (3) redefine the term \u201cinsanity,\u201d (4) revise the procedures governing petitions for the transfer or release of defendants found not guilty by reason of insanity, and (5) create new procedures for certain sentencing hearings.\nSection 45 amends the Code of Civil Procedure (735 ILCS 5/1\u2014 101 et seq. (West 1996)) to state that the homestead exemption does not apply to property subject to certain drug asset forfeiture proceedings.\nSection 50 amends the Hospital Lien Act (770 ILCS 35/0.01 et seq. (West 1996)) to (1) create a new title for that act, (2) include within that act all hospitals operated by a unit of local government, and (3) revise the procedures for the perfection and attachment of hospital liens.\nIn sum, Public Act 89 \u2014 404 addresses at least five legislative subjects and amends nine statutory codes covering both civil and criminal matters.\nB. GOVERNING LAW\nFound in article IV, section 8, of the Illinois Constitution of 1970, the single subject rule provides, in pertinent part:\n\u201cBills, except bills for appropriations and for the codification, revision or rearrangement of laws, shall be confined to one subject.\u201d 111. Const. 1970, art. IV, \u00a7 8(d).\nBecause the single subject rule is a substantive, rather than a procedural, requirement for the passage of bills, an alleged violation of the rule is subject to judicial review. Johnson, 176 Ill. 2d at 514.\nIn a recent decision, the Illinois Supreme Court explained that the single subject rule serves two purposes. First, the rule exists to prevent the passage of legislation that, standing alone, could not muster the votes necessary for passage. Johnson, 176 Ill. 2d at 514; see also Geja\u2019s Cafe v. Metropolitan Pier & Exposition Authority, 153 Ill. 2d 239, 258 (1992). Characterizing the practice as \u201clog-rolling,\u201d the Illinois Supreme Court regards the combining of several unpopular and unrelated measures into one popular omnibus bill as \u201c \u2018 \u201cboth corruptive of the legislator and dangerous to the State.\u201d \u2019 \u201d Geja\u2019s Cafe, 153 Ill. 2d at 257-58, quoting Fuehrmeyer v. City of Chicago, 57 Ill. 2d 193, 202 (1974), quoting People ex rel. Drake v. Mahaney, 13 Mich. 481, 494-95 (1865).\nThe second purpose of the single subject rule is the facilitation of an \u201corderly legislative procedure.\u201d Johnson, 176 Ill. 2d at 514. Given the volume of legislation that is introduced in the legislature each year, an individual legislator may be unable to appreciate all of the nuances and implications of a bill containing numerous unrelated provisions. By limiting each bill to a single subject, the legislature can better grasp and more intelligently discuss the issues each bill presents. Johnson, 176 Ill. 2d at 514-15, citing M. Rudd, No Law Shall Embrace More Than One Subject, 42 Minn. L. Rev. 389, 391 (1958). Thus, the single subject rule is designed also to ensure that the legislature directly addresses the difficult decisions it faces. Johnson, 176 Ill. 2d at 515.\nThat said, in the constitutional sense, the term \u201csubject\u201d is comprehensive in scope and must be construed liberally. People v. Dunigan, 165 Ill. 2d 235, 255 (1995). So long as the provisions of a bill have a \u201cnatural and logical connection,\u201d the subject of that bill may be as broad as the legislature chooses. Johnson, 176 111. 2d at 515. The legislature violates the single subject rule only when it includes within a single bill incongruous and unrelated matters that by no fair intendment have any legitimate relation to each other. Johnson, 176 Ill. 2d at 515; Dunigan, 165 Ill. 2d at 255.\nC. ANALYSIS\nIt is well established that legislative enactments enjoy a heavy presumption of constitutionality. In re Marriage of Lappe, 176 Ill. 2d 414, 422 (1997). Moreover, the single subject rule does not impose an onerous restriction on the legislature\u2019s actions but rather leaves the legislature with wide latitude in determining the content of bills. Johnson, 176 Ill. 2d at 515. As the Illinois Supreme Court has noted, the legislature \u201cmust indeed go very far to cross the line to a violation of the single subject rule.\u201d Johnson, 176 Ill. 2d at 515-16.\nWith these principles in mind, we hold that, in enacting Public Act 89 \u2014 404, the legislature clearly crossed the line and violated the single subject rule of the Illinois Constitution. Public Act 89 \u2014 404 began as a narrowly tailored bill confined solely to the use of the insanity defense in criminal proceedings. As enacted, Public Act 89\u2014 404 addresses no less than five distinct legislative subjects and amends nine different statutory codes covering both civil and criminal matters. Among Public Act 89 \u2014 404\u2019s highlights are (1) the removal of the homestead exemption from property subject to certain civil forfeiture proceedings, (2) an increase in the burden of proof for a criminal defendant asserting the insanity defense, (3) truth-in-sentencing legislation, and (4) new procedures for the perfection and attachment of hospital liens. After long and careful reflection, this court simply is unable to identify the \u201cnatural and logical connection\u201d uniting civil forfeiture, criminal sentencing, and hospital liens. Accordingly, we hold that Public Act 89 \u2014 404 violates the single subject rule and therefore is unconstitutional in its entirety.\nIn reaching this conclusion, we note that, according to the legislative debates surrounding Senate Bill 1187, Senate Bill 1187\u2019s violation of the single subject rule led directly to the evils that the single subject rule was designed to prevent. Again, when the Senate sent Senate Bill 1187 to the House, the bill addressed only the use of the insanity defense in criminal proceedings. When Senate Bill 1187 returned from the House, it contained 10 sections addressing a broad range of both criminal and civil subjects. Explaining the bill\u2019s metamorphosis to his colleagues, Senator Dillard, Senate Bill 1187\u2019s chief sponsor, stated that, although truth-in-sentencing was \u201cthe major part of the [House\u2019s] amendment,\u201d that amendment \u201calso adds a number of other bills that passed almost unanimously over in this Body earlier this year.\u201d (Emphasis added.) 89th Ill. Gen. Assem., Senate Proceedings, May 24, 1995, at 60 (statements of Senator Dillard). Thus, although the Senate originally considered each of Senate Bill 1187\u2019s various provisions in separate bills, the House amendment now forced the Senate to consider them era masse.\nLater in the debate, Senator Cullerton recognized the dilemma presented by the House\u2019s drastic revision of Senate Bill 1187: The Illinois Supreme Court has explained that the single subject rule exists \u201cto prevent the combination of unrelated subjects in one bill to obtain support for the package as a whole, when the separate parts could not succeed on their individual merits.\u201d County of Kane v. Carlson, 116 Ill. 2d 186, 214 (1987). Although we have no way of knowing whether Senate Bill 1187\u2019s separate parts could have succeeded on their individual merits, Senator Cullerton\u2019s comments confirm that, with respect to Senate Bill 1187, the purposes of the single subject rule were not served.\n\u201cThere are some things that were thrown in here, like all conference committees that \u2014 are things which I would perhaps not wish to vote for, because there must be at least ten or fifteen bills. But overall, the main part of the bill is the truth-in-sentencing ***. And I also urge an Aye vote.\u201d (Emphasis added.) 89th Ill. Gen. Assem., Senate Proceedings, May 24, 1995, at 65 (statements of Senator Cullerton).\nNevertheless, the State offers two theories to support Public Act 89 \u2014 404\u2019s constitutionality. First, the State insists that an examination of Public Act 89 \u2014 404\u2019s title reveals that Public Act 89 \u2014 404 embraces a single subject: governmental matters. We find that this \u201csubject\u201d is too broad to satisfy the Illinois Constitution\u2019s mandates. See Johnson, 176 111. 2d at 515 (a statute\u2019s substantive provisions must have a \u201cnatural and logical connection\u201d). After all, every legislative enactment is, by definition, a \u201cgovernmental matter.\u201d For example, a survey of the index to the Illinois Compiled Statutes reveals that every heading relates to a matter involving the government. As a result, we find that, to satisfy the single subject rule, the subjects in a statute must have something in common other than the fact that they all address some aspect of the government. Indeed, by suggesting that the legislature may include anything within a single bill as long as it relates to a \u201cgovernmental matter,\u201d the State is, in effect, arguing for the single subject rule\u2019s repeal. Accordingly, we respectfully reject the State\u2019s position.\nThe State next argues that Public Act 89 \u2014 404 is constitutional because it is a \u201crevisory bill\u201d and therefore exempt from the single subject rule. According to the State, Public Act 89 \u2014 404 is revisory because it does not create any new statutes but merely amends existing provisions of existing legislation.\nThe State misunderstands the meaning of \u201crevisory bill.\u201d As the Illinois Supreme Court has explained, for purposes of the single subject rule, a revisory bill is one that makes no substantive changes and adds no new matter to existing legislation. People v. Bullard, 61 Ill. 2d 277, 278, 283-84 (1975); see also Heitz v. Hogan, 134 Ill. App. 3d 352, 358 (1985). Instead, a revisory bill merely incorporates the provisions of prior legislative amendments. Bullard, 61 Ill. 2d at 278, 283-84; Heitz, 134 Ill. App. 3d at 358. Under this definition, Public Act 89 \u2014 404 is not a revisory bill. Public Act 89 \u2014 404 makes substantive changes to numerous existing statutes, including the Counties Code, the Illinois Municipal Code, the Criminal Code of 1961, the Code of Civil Procedure, and the Hospital Lien Act. In addition, Pub-lie Act 89 \u2014 404 adds new matter to several existing statutes, including the Unified Code of Corrections and the Code of Criminal Procedure of 1963. Finally, Public Act 89 \u2014 404 incorporates the provisions of no prior legislative amendments. Thus, under Bullard and Heitz, Public Act 89 \u2014 404 fails every measure of a revisory bill. We therefore conclude that Public Act 89 \u2014 404 is not exempt from the single subject rule.\nIn sum, we conclude that Public Act 89 \u2014 404 violates the single subject rule of the Illinois Constitution of 1970 and therefore is invalid and unenforceable in its entirety. We emphasize, however, that our ruling does not address the substantive constitutionality of Public Act 89 \u2014 404\u2019s individual components. Rather, our ruling goes only to Public Act 89 \u2014 404\u2019s structure and the manner in which it was enacted. Thus, the legislature is free to revisit Public Act 89 \u2014 404\u2019s various provisions in future legislation. See Johnson, 176 Ill. 2d at 512.\nIII. THE EQUAL PROTECTION CLAUSE\nHaving concluded that Public Act 89 \u2014 404 was enacted in violation of the single subject rule of the Illinois Constitution of 1970, we need not address defendant\u2019s argument that the truth-in-sentencing provisions contained in section 3 \u2014 6\u20143(a)(2)(ii) of the Unified Code of Corrections (730 ILCS 5/3 \u2014 6\u20143(a)(2)(ii) (West 1996)) violate the equal protection clause.\nIV. CONCLUSION\nWe conclude that Public Act 89 \u2014 404 is unconstitutional in its entirety and that the State of Illinois and all of its officers and agents are permanently enjoined from enforcing any and all of its provisions. Defendant therefore is eligible to receive the good-conduct credit that he would have been eligible to receive prior to Public Act 89 \u2014 404\u2019s enactment.\nFor the foregoing reasons, the judgment of the circuit court of Lake County is affirmed as modified.\nAffirmed as modified.\nCOLWELL and THOMAS, JJ., concur.", "type": "majority", "author": "JUSTICE McLAREN" } ], "attorneys": [ "G. Joseph Weller and Patrick M. Carmody, both of State Appellate Defender\u2019s Office, of Elgin, for appellant.", "Michael J. Waller, State\u2019s Attorney, of Waukegan (Martin P. Moltz, of State\u2019s Attorneys Appellate Prosecutor\u2019s Office, of counsel), and Sharon M. Neal, of Arlington Heights, for the People." ], "corrections": "", "head_matter": "THE PEOPLE OF THE STATE OF ILLINOIS, Plaintiff-Appellee, v. GARY REEDY, Defendant-Appellant.\nSecond District\nNo. 2\u201496\u20140101\nOpinion filed March 11, 1998.\nG. Joseph Weller and Patrick M. Carmody, both of State Appellate Defender\u2019s Office, of Elgin, for appellant.\nMichael J. Waller, State\u2019s Attorney, of Waukegan (Martin P. Moltz, of State\u2019s Attorneys Appellate Prosecutor\u2019s Office, of counsel), and Sharon M. Neal, of Arlington Heights, for the People." }, "file_name": "0034-01", "first_page_order": 54, "last_page_order": 64 }