People v. Koen

Illinois Appellate Court
Criminal Court
Citation
Case Number: 
2014 IL App (1st) 113082
Decision Date: 
February 7, 2014
District: 
1st Dist.
Division/County: 
Cook Co., 6th Div.
Justice: 
REYES
Holding: 
Affirmed.
Defendant was convicted, after jury trial, of theft and forgery. Actions taken by a nonprofit's officers, directors and members during time between dissolution and reinstatement are valid actions of nonprofit as if it had not been dissolved, General Not for Profit Corporations Act does not authorize any person to "purport to act" as officer of dissolved entity to sign documents of reinstatement. State can fairly contradict implication of reinstatement of corporation with comment, a conclusion supported by witness testimony, as comment in rebuttal was invited by remarks in closing argument of defense counsel.(ROCHFORD and PIERCE, concurring.)