People v. Brown

Lower court bench ruling that defendant was guilty of unlawful possession of a weapon by a felon and armed violence violated one-act, one-crime principals. Defendant’s conduct was a single act, because both convictions were based on the same physical act of Defendant possessing a gun. Under the armed violence conviction, defendant was armed with a handgun while also possessing cocaine, and under the other conviction, he possessed a firearm as a felon. Defendant’s felon status was not “an overt or outward manifestation” but an element of the offense. Thus, Defendant’s multiple convictions were improper, and the less serious conviction must be vacated.