Illinois Appellate Court
Criminal Court
Motion to Suppress
One-Act
One-Act-One-Crime Doctrine
Following a stipulated bench trial, defendant was convicted of identity theft, possession of a fictitious or unlawfully altered driver’s license, and unlawful possession of a theft detection device remover. She appealed arguing that the trial court erred when it denied her motion to suppress evidence and that her convictions violated the one-act, one-crime rule. The appellate court affirmed in part and vacated in part, finding that the trial court did not err when it denied defendant’s motion to suppress but that the convictions for identity theft and possession of an unlawfully altered driver’s license must be vacated under the one-act, one-crime rule. (JORGENSEN and BIRKETT, concurring)