People v. Brown

Illinois Supreme Court PLAs
Criminal Court
One-Act-One-Crime Doctrine
Citation
PLA issue Date: 
November 28, 2018
Docket Number: 
Nos. 123901 and 123902 Cons.
District: 
1st Dist.

This case presents question as to whether defendants’ convictions for robbery and aggravated battery of senior citizen violated one-act-one-crime doctrine, where record showed in both cases that defendant’s convictions arose out of single act of punching victim. Appellate Court, in vacating defendants’ aggravated battery of senior citizen conviction, found that said conviction violated said doctrine, since there was no other evidence of other use of force, threat of force, or verbal threat to victim. In its petitions for leave to appeal, State argued that there is no violation of one-act-one-crime doctrine, where record showed existence of two physical acts, i.e. punching victim that could support both convictions and taking victim’s money that could only support robbery conviction.