Illinois Appellate Court
Criminal Court
Firearm Owners Identification Card Act (FOID)
Defendant was convicted, after jury trial, of aggravated unlawful use of a weapon for carrying weapon without valid FOID card, and offense was elevated to Class X felony as he wore body armor. Officer’s testimony about bulletproof vest Defendant had been found wearing was properly admitted as lay opinion, as it was based on his personal observations and was of type officer was generally capable of making. No specialized knowledge is required to opinion as to whether vest was body armor per Criminal Code. Section of Criminal Code under which Defendant was convicted is limited to those lacking FOID card, and is thus not facially unconstitutional. (HYMAN and MASON, concurring.)