People v. Bush, 37 N.E.3d 903

Nathan Bush was arrested possessing pseudoephedrine (methamphetamine precursor), lithium batteries, “Heet” (isopropyl alcohol), and cold packs.
Charged with two counts under the Methamphetamine Control and Community Protection Act: (1) possession of methamphetamine precursor (720 ILCS 646/20(a)(1)); (2) possession of methamphetamine-manufacturing materials (720 ILCS 646/30(a)).
Photo of seized items admitted; jury convicted Bush on both counts.
Court sentenced Bush to five years' imprisonment and two years mandatory supervised release on each count, to run concurrently; Bush did not object at sentencing.
On appeal Bush argued his convictions violated the one-act, one-crime rule and one conviction should be vacated.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether two convictions violate the one-act, one-crime rule	The offenses arise from separate statutory possessions of different items and thus support separate convictions	Bush: all items were possessed in a single act of possession, so only one conviction should stand	Affirmed: two distinct acts of possession exist; concurrent convictions are proper

People v. King, 66 Ill.2d 551 (1977) (establishes one-act, one-crime rule and allows concurrent convictions where offenses are not lesser-included and arise from distinct acts)
People v. Rodriguez, 169 Ill.2d 183 (1996) (multiple convictions allowed when a second overt manifestation supports a separate offense)
People v. Enoch, 122 Ill.2d 176 (1988) (issue preservation rules; failure to object at sentencing may waive challenge)
People v. Smith, 183 Ill.2d 425 (1998) (plain-error doctrine overview for review of unpreserved errors)
People v. Artis, 232 Ill.2d 156 (2009) (one-act, one-crime challenges reviewed de novo)
In re Samantha V., 234 Ill.2d 359 (2009) (one-act, one-crime violation implicates judicial integrity and may fit plain-error review)