is the prohibition conviction the geographic restriction contained in dustin's probation included in dustin's probation was a geographical restriction that are to him from entering the university of illinois campus this supreme court held that for a probation condition which restricts geographic movement to be constitutional there one must be a valid purpose and there must be an exemption here or there is an exemption today dustin is only challenging whether they say for there to be a valid purpose there has to be a nearly dry and reasonably related relationship between the geographical shipshape and the nature of the offense or the rehabilitation and if you look to be analysis done by our supreme court in g w they looked at specific arctic you all facts between the offense and between the rehabilitation and the offense committed and here in the record there was no mention of the university of illinois now the prosecutor defense counsel nor the judge mention the university and as i stated earlier there were no findings made regarding this restriction and garners there was no need for the court to mention the university of illinois or there is no need because this offense happen on eight hundred twelve north kind which is not on the university's campus nothing in the record has dust in h arguing it is and i want to hear your your explanation as to why the court may not find itself find that it is unreasonable for a sec but taking a step back from that it's still a must find it reasonable within the constitutional confines described in j w and that is this closely related to require and there's nothing in the record that mentions the university nothing on the record that anything regarding the offense for dust than to the probation condition and the reason our supreme court explain why this analysis in this relatedness requirement is necessary is because the freedom of movement impacts a fundamental constitutional rights closely intertwined with the freedom of speech freedom of assembly freedom of association and that's why there is this higher scrutiny attash to probation conditions that restrict geographic movement and look into the analysis of in a regime w there is not that relatedness component here there were new findings made there was nothing in the record besides this geographically sure action that even mentioned there is still no connection between justin's offense and his rehabilitation so he had to have you know he would have had to have committed his armed robbery on the campus before the court could say stay away from the campus not necessarily but there had to be when these probation conditions can be ordered and it's order to foster rehabilitation and you concentrated on that and protecting the public justice if judge lad was concerned about protecting the public she might have more narrowly defined this restriction such as no going on the universe on a campus after say six o'clock you cannot enter into a dorm room house but this is so very were those have been ok i believe so because i believe in that situation there could have been an argument that dorms presents an area especially after hours where a thirteen year olds should not maybe attend college parties etc but in this situation you never should on a campus so sprawl ruc champaign urbana that dustin's freedom of movement is restrictive could he hop on a city bus most city buses likely go through some part of campus he would be in violation of his probation could he go to a basketball or football game he walked across the quad go to the many public libraries and that is why would be unconstitutional no i believe if you committed on the campus there according to the analysis done in g w there would have been not relatedness in order to satisfy the constitutionality but when there's nothing you know you might still the campus according to the analysis for would it would be constitutional but the argument here breaks down because there's nothing there's no connection at all how about this for a possible rationale  illinois and has read about the crime in champaign urbana of it also notes that in the sentencing of these particular criminals there have been or conditions of probation placed on the individual that back individual may not enter the your body campus might provide a little piece of mind for the parent i'm throwing something out there can you address that would there be a legitimate interest such that it would support a condition of probation here i think that where we talk about legitimate interests i hear you referring to the rational basis test because my understanding when reading j w is that there's a higher level of scrutiny because the the opinion talks about narrow state your honor this is a thirteen year old finn who's been been convicted of armed robbery it's in it's in the best interest of this community of the champagne community she was sure that this you know this defendant's movement in this area because while we don't want armed robber you know it might happen in other cases where you know in other parts of the city but this is a special central hub in the champagne area this is where thousands of students go they all ten and we also know the dangers of the city convicted of armed robbery and i suggest that even though it's not merely it's i would suggest that this defendant is highly susceptible to these kind of crimes with as my opposing counsel said his codefendant suggest and commit this crime and he did and he committed this crime at night and he usually runs away at night and as we all know no good deeds happen after midnight we're in springfield right now the university of illinois a think even i don't think he can be arrested but i don't think even though as were opposing counsel it was overly overly broad i think that condition was only applied to champagne even though i didn't say and it's order  the crime occurred in champagne you know and the recommendation in the post and the report it said that you know the defendant should be sued should refrain from you know the schools and champagne so i would assume i would suggest that the defendant should only be should be refrain from entering the campus university and champaign as such like i said your honor the defense is highly susceptible to these on two influences  curfew because that's also included but if you were to go to this campus he most likely engaged in these activities which we don't want the state wants him to you know become active of active member of our society he had better you know get those  great so you can go to college but by constantly running away you know engaging in other crimes and this just doesn't help him you know even at all trying to get college this or her probation doesn't restrict him from he should be frank from the other school the only door just states that it should be this city of campus in champaign what vertebral also in the posts in the wreck of the report that's by the post sentencing report it said and i made sure i made sure i read this correctly it said it recommended that the defendant should be free frayne from other city or other schools in champaign but the the court didn't put that into its order  off the probation office and while it doesn't specifically state and the order the probation office normally or more most likely put these orders and two minor cases like to defend here d it's because the trial court and the probation office they know what these activities are on this and that area there know they know the dangers in know what kind of life happens and this is one even though i didn't specifically state in the order i would assume that the trial court took this in sick consideration and that's why the trial court prohibited the defendant from entering these things additionally your honor i don't i would like to ourselves not to divorce yourself from reality you know this is a thirteen year old boy who is not allowed to go anywhere at his leisure i'm assuming if not most of us are some of you are all parents i wouldn't want my thirteen year old child to go onto a campus all by himself at night so he can do as you please he just can't do that  on the us state mentions that there is an exemption and there isn't scales but there are two distinct analyses in determining whether or not condition is constitutional one is whether there is an exemption s what i'm saying i'm sorry what i'm arguing is that regardless of the exception there still is this relatedness requirement and that is why the supreme court has seemingly instituted this higher level of scrutiny rights as our supreme court stated in the state example of going on to the university of illinois campus maybe going to parties that night judge black could have imposed a narrow restriction regarding you cannot enjoy the univers about his offense and how it related to his rehabilitation and not surrounding himself with or without that explanation of the record it would be ok i think without any thing more narrow it would not be ok because right now just that it's not a serious issue for the theaters were i don't believe so i believe that it is serious because again this is a fundamental right that is being restricted serious in their minds as far as the scope of this if they were