People v. Coats

Defendant was convicted, after bench trial, of several offenses, including being an armed habitual criminal and armed violence. Under the one-act, one-crime analysis, Defendant's conduct consisted of multiple acts. A defendant's status is not factored into the analysis to determine whether a defendant's conduct consists of one act or several acts. The gun possession and the drug possession were separate acts.When the issue of lesser-included offenses arises in the context of a one-act, one-crime issue where the defendant was convicted of both offenses, the abstract elements approach is to be applied, as opposed to determining whether an uncharged offense is a lesser-included offense to a charged offense using the charging instrument approach. The one-act, one-crime rule did not prohibit Defendant's multiple convictions as they were separate acts. (KARMEIER, FREEMAN, THOMAS, KILBRIDE, GARMAN, and BURKE, concurring.)