Defendant was found guilty of one count of creation of child pornography, one count of aggravated criminal sexual abuse, and one count of possession of child pornography and sentenced to concurrent sentences totaling 25 years. Defendant appealed, arguing that his conviction for possession of child pornography violated the one-act, one-crime doctrine because it was based on the same act as his conviction for creation of child pornography. The appellate court affirmed, finding that the conviction did not violate the one-act, one-crime doctrine because there were intervening events between the recording of the videos at issue, which supported the conclusion that they were multiple acts and not a single act and that defendant’s actions indicated an intent to retain possession of the videos after they were made. (McBRIDE and REYES, concurring)
Illinois Appellate Court
Criminal Court
One Act
One Crime Doctrine