People v. Beauchamp, 241 Ill. 2d 1

Defendants Beauchamp and Jones were charged by indictment with burglary of a motor vehicle for entering Little's SUV with intent to commit theft.
At trial, Little testified the rear hatch window of her SUV had been punched out and removed, with one hydraulic arm detached, after the window previously opened via a button.
Officer Frazier observed two men (Beauchamp driver, Jones passenger) in a nearby white car with Little's missing rear window in the backseat.
The State argued punching the lock and removing the window constituted entry; the defense contended there was no entry if only the window was breached from outside.
Appellate court trimmed Beauchamp and Jones convictions to theft, remanding for resentencing; the State sought reversal and reinstatement of burglary convictions.
Illinois Supreme Court reversed the appellate court, reinstating burglary convictions and sentences for both defendants.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was there sufficient entry into the vehicle?	Beauchamp	Beauchamp	Yes; entry proved beyond reasonable doubt
Did Jones actively participate or merely as a passenger?	Jones participated	Jones was only a passenger	Jones properly convicted as participant
Should the appellate court's modification to theft be reinstated or burglary affirmed?	The State	Beauchamp/Jones	Reversed; burglary convictions and sentences reinstated

People v. Sutherland, 223 Ill. 2d 187 (2006) (sufficiency review standard)
People v. Collins, 106 Ill. 2d 237 (1985) (standard for reviewing factual sufficiency)
People v. Cunningham, 212 Ill. 2d 274 (2004) (allowing inferences in sufficiency review)
People v. Parham, 377 Ill. App. 3d 721 (2007) (entry by breaking the close)
People v. Frey, 126 Ill. App. 3d 484 (1984) (entry by reaching into a space with a tool)