People v. Ryan

Defendant was convicted of possession of a firearm while ineligible for a FOID card, two counts of unlawful use of a weapon, and violation of the conditions of his bail bond. On appeal, defendant argued that the trial court erred by conducting a bench trial on stipulated evidence over a videoconference and that the latter three counts should be vacated on one-act, one-crime principles. The appellate court reversed and remanded, finding that conducting a bench trial on stipulated evidence via videoconferencing without defendant’s knowing consent to do so was structural error. (SCHOSTOK and KENNEDY, concurring)