In People v. Whitfield, 217 Ill. 2d 177, 840 N.E.2d 658, 298 Ill. Dec. 545 (2005), the defendant argued that the court erred in dismissing his postconviction claim that the trial court's failure to admonish him that a three-year MSR term would be added to his negotiated 25-year prison sentence violated his fundamental rights. Whitfield, 217 Ill. 2d at 180. Our supreme court determined that the defendant had not received the benefit of the bargain to plead guilty because he agreed to a 25-year sentence but was never told of the three-year period of MSR which attached to his sentence as an operation of law. Whitfield, 217 Ill. 2d at 188. The court concluded that the appropriate remedy was to modify defendant's 25-year sentence to a term of 22 years, to be followed by the mandatory 3-year term of supervised release. Whitfield, 217 Ill. 2d at 205. The supreme court noted that a violation of due process occurs when a defendant pleads guilty in exchange for a specific sentence, but receives "a different, more onerous sentence." Whitfield, 217 Ill. 2d at 189. The Whitfield court further observed that under Supreme Court Rule 402(a)(2) (177 Ill. 2d R. 402(a)(2))--which requires the trial court to inform the defendant of the minimum and maximum sentences prescribed by law before accepting a guilty plea--the defendant must be informed that a term of MSR will be added to his or her sentence. Whitfield, 217 Ill. 2d at 188, citing People v. Wills, 61 Ill. 2d 105, 109, 330 N.E.2d 505 (1975). Without a proper admonition, adding MSR to the defendant's sentence "amounts to a unilateral modification and breach of the plea agreement by the State, inconsistent with constitutional concerns of fundamental fairness." Whitfield, 217 Ill. 2d at 190. However, because a defendant sentenced to imprisonment must also serve a term of MSR, the Whitfield court concluded that the remedy most closely approximating the defendant's bargain with the State is to reduce the defendant's prison term by a period equal to the MSR term. Whitfield, 217 Ill. 2d at 203-05. Accordingly, in Whitfield, where the defendant pleaded guilty in exchange for a 25-year prison term and was not told he would also have to serve a 3-year term of MSR, the court reduced the prison term by 3 years. In Whitfield, the court explained that, where the defendant is not properly admonished, "there are two separate, though closely related, constitutional challenges that may be made: (1) that the plea of guilty was not made voluntarily and with full knowledge of the consequences, and; (2) that defendant did not receive the benefit of the bargain he made with the State when he pled guilty." Whitfield, 217 Ill. 2d at 183-84. The second type of challenge proceeds upon the theory that, absent the requisite admonishment, addition of the MSR term to the agreed-upon sentence "violates due process because the sentence imposed is more onerous than the one defendant agreed to at the time of the plea hearing." Whitfield, 217 Ill. 2d at 195. The defendant in Whitfield sought to enforce, as nearly as possible, his bargain with the State. He had agreed to serve a 25-year prison term for first-degree murder, but not the 3-year term of MSR imposed by operation of law (730 ILCS 5/5--8--1(d)(1) (West 1998)). The court held that MSR could not be stricken from the sentence; rather, the appropriate remedy was to reduce the defendant's prison term by three years--the length of the MSR term.