People v. Ulloa

Defendant was convicted, after jury trial, of conspiring to deliver cocaine. Court misstated applicable law by its use of accountability instruction and insertion of accountability language in issues instruction was plain error, requiring reversal, as evidence was closely balanced. On remand, court must instruct jurors that to find Defendant guilty as charged, they must find that he personally agreed to delivery of more than 900 grams of a substance containing cocaine. Court did not abuse its discretion in admitting testimony that Defendant bought a money counter and a heat sealer from a store in Cicero 11 months prior to encounter in issue. (PIERCE, specially concurring; LIU, concurring.)