People v. Grant

Illinois Appellate Court
Criminal Court
Firearm Owners Identification Card Act (FOID)
Citation
Case Number: 
2014 IL App (1st) 100174-B
Decision Date: 
Monday, December 15, 2014
District: 
1st Dist.
Division/County: 
Cook Co.,1st Div.
Holding: 
Affirmed in part and reversed in part.
Justice: 
CUNNINGHAM
Defendant was convicted, after bench trial, of violations of aggravated unlawful use of a weapon (AUUW) statute and violation of FOID Card Act. There was corroborating evidence apart from Defendant's admission, as officer testified that no FOID card was found on Defendant's person and Defendant never presented one, even when officer asked whether he had one. As FOID-related sections of AUUW statute and FOID Card Act do not require identical elements to establish criminal liability, they do not violate proportionate penalties clause of Illinois Constitution. (HOFFMAN and ROCHFORD, concurring.)