People v. Hartfield

The Illinois Supreme Court held that the firing of a single shot in the direction of multiple peace officers does not support multiple convictions for aggravated discharge. The court explained that the number of “victims” does not control the unit of prosecution. The court looks instead to the language of the statute to determine the intent of the legislature and will resolve any doubt against construing the statute in a manner that supports multiple instances of the same offense for the same singular act. With regard to aggravated discharge, the court found no express definition of the unit of prosecution contained in the language of the statute and, applying the doctrine of lenity, the court concluded that a single discharge in the direction of multiple peace officers constitutes a single offense.  (ANNE M. BURKE, THEIS, MICHAEL J. BURKE and OVERSTREET, concurring. CARTER and NEVILLE, specially concurring.)