Leonard was tried and convicted for lewd acts on children and was sentenced in 1989. He was released on probation in 1993, and allegedly violated probation in 1995 and was ordered back to prison for a term of 30 years. He appealed, arguing that one of his 1989 sentences was illegal. On appeal, the Second District Court held that this claim was barred because he failed to properly object as required by the Criminal Appeal Reform Act.