People v. Sharpe , No. Defendant then filed a timely pro se petition for postconviction relief. The circuit court summarily dismissed the petition as frivolous and without merit. Although this issue was not presented in the circuit court, defendant is not precluded from raising it on appeal. Ill. Const. 1970, art.
Defendant argues that the purpose of the legislation was to alleviate prison overcrowding.
Provisions expanding the scope of the offense of threatening a public official and narrowing the scope of postconviction relief, he contends, contravene that purpose. Because of the similarity of the stated subject of that act to Public Act 83-942, we believe that Malchow provides more guidance than Cervantes . In Malchow , our supreme court first observed that the stated subject is to be construed liberally in favor of upholding the legislation. Then, examining the various provisions of the legislation, the court determined that all of the provisions related to the stated subject. The court concluded, therefore, that the act was valid.