Illinois Supreme Court

People v. Collins

May 21, 20262026 IL 131300

Summary

The Illinois Supreme Court held that Illinois common law and section 3-4(b)(2) of the Criminal Code provide issue-preclusion protections broader than the federal constitutional rule discussed in Currier. Because Collins’s acquittal on the felon-in-possession charge necessarily determined that he did not knowingly possess the firearm, the State could not relitigate possession in the aggravated unlawful use of a weapon prosecution, and Collins did not waive that protection by requesting severance. The court affirmed the appellate court and reversed the circuit court.