Illinois Appellate Court
Criminal Court
Closing Arguments
Defendant was convicted, after jury trial, on all counts relating to manufacture and possession of methamphetamine. Convictions are not based upon precisely the same physical act, but based on separate and distinct acts, and thus do not violate the one-act, one-crime rule. Possession is not a lesser-included offense of participating in manufacturing. Although errors occurred in closing argument of State, evidence against Defendant was overwhelming, and errors were not so serious that a structural error occurred. (HOLDER WHITE and TURNER, concurring.)