In Illinois v. Talley, 177 Ill. App. 3d 170, 171, 531 N.E.2d 1139, 126 Ill. Dec. 512 (1988), the defendant appealed his armed robbery conviction by arguing that the trial court's "failure to instruct as to a mental state when giving the elements instruction for armed robbery" deprived him of his right to a fair trial. The Illinois armed robbery statute required violating the state's robbery statute -- which mirrors the Commonwealth robbery statute -- while armed with a dangerous weapon. Id. prosecution in Talley used the Illinois Pattern Jury Instructions, which, like the statute at issue, did not reference a mental state. Id. at 173. Talley argued that since armed robbery was "not a crime of absolute liability," by implication, a mental state must be read into the statute, and that failure to instruct as to this mental state constituted reversible error. Id. at 171-72. Upholding the trial court conviction, the Illinois Court of Appeals held that where the charged offense "is a general intent crime and the mental state is necessarily implied by the crime, it is not error to omit the implied mental state from the issue instructions." Id. at 174. In support of its ruling, the court reasoned that, "it is obvious that the commission of the general intent crimes of criminal sexual assault, robbery, or armed robbery, as defined by the statutes, necessarily implied an intent or knowledge," while in contrast, "specific intent offenses . . . would not necessarily imply a criminal mental state . . . and in those cases, the mental state would be a necessary subject of the jury instruction." Id.