People v. Coats

This case presents question as to whether defendant’s convictions for armed habitual criminal and armed violence violated one-act, one-crime doctrine, where record showed that defendant possessed only one gun. Appellate Court, in affirming both convictions, noted split of authority on said issue, but found that both convictions could stand since they were based on separate acts, where defendant’s armed habitual criminal conviction required additional element of his status as offender with two prior felony convictions, and where defendant’s conviction for armed violence required additional act of possession of heroin with intent to deliver. Moreover, neither offense qualified as included offense of other offense.