People v. Fields

Illinois Appellate Court
Criminal Court
Firearm Owners Identification Card Act (FOID)
Citation
Case Number: 
2022 IL App (4th) 210194
Decision Date: 
Tuesday, September 20, 2022
District: 
4th Dist.
Division/County: 
Woodford Co.
Holding: 
Affirmed.
Justice: 
TURNER

Defendant was found guilty of unlawful possession of a weapon with a revoked FOID card and sentenced to two years in prison with one year of mandatory supervised release. Defendant argued on appeal that the trial court erred in denying her motion to suppress evidence found during a traffic stop, that the State failed to prove that she was reckless in not knowing that her FOID card had been revoked, or, in the alternative, that the trial court erred when it barred defendant from presenting evidence that she was not aware of the revocation. The appellate court affirmed, finding that defendant did not file a timely post-trial motion and, as a result, her arguments raised on appeal were forfeited. The appellate court further found that while the traffic stop was “unusual” there was no evidence presented that it was racially motivated, that a defendant could be convicted of possession with a revoked FOID card even if the card was valid on its face, and that the trial court did not commit a “clear or obvious” error in its interpretation of the statute. (HARRIS and CAVANAGH, concurring)