People v. Sotelo

Defendant was convicted, after bench trial, of various offenses including three counts of unlawful possession of a firearm without FOID card, based on his possession of three different firearms and one box of ammunition. Singular act of failing to possess FOID card cannot sustain multiple convictions of an offense comprised solely of that act, but that act may serve as common element of multiple offenses that include additional physical acts (possession of different firearms or of firearm ammunition) as elements. Possession of multiple firearms without FOID card will support only one conviction, but separate conviction based on possession of firearm ammunition without FOID card may also stand. (HUTCHINSON and BURKE, concurring.)