People v. Coats, 104 N.E.3d 1102

Police executed a search warrant at a Chicago basement apartment and forced entry into a locked rear room, where Officer Utreras saw Coats holding a .45 handgun in one hand and two plastic bags in the other.
The handgun was loaded; the bags contained suspected heroin and crack; testing and stipulation confirmed over 15 grams of heroin in the bags Coats held.
Coats was convicted after a bench trial of armed habitual criminal, armed violence (based on possession of drugs while armed), and two counts of possession with intent to deliver; the possession counts merged into armed violence.
Sentences: 7 years for armed habitual criminal, consecutive to 15 years for armed violence (consecutive term mandated by statute because armed violence was predicated on a controlled-substance violation).
On appeal Coats argued (for the first time) that the armed-violence and armed-habitual-criminal convictions violated the one-act, one-crime rule because both depended on the single physical act of possessing the gun.
The Illinois Supreme Court allowed review and affirmed the appellate court: the conduct involved multiple acts (gun possession and drug possession), so multiple convictions were proper.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether one-act, one-crime barred convictions for armed violence and armed habitual criminal	State: multiple convictions permissible when offenses rest on separate acts	Coats: both convictions rest on the same physical act of possessing the gun, so one must be vacated	Held: No violation — defendant committed multiple acts (gun possession and drug possession); convictions stand
Whether the error (if any) is reviewable under plain-error doctrine	State: defendant forfeited the issue by not raising it at trial	Coats: seeks plain-error review	Held: Court reviewed under the second prong (error affecting integrity of judicial process) but found no one-act, one-crime error
Whether the offenses are lesser-included offenses of each other	Coats contended overlap might make one offense lesser-included	State: offenses have distinct elements	Held: Using abstract-elements approach, offenses are not lesser-included; appellate court’s charging-instrument reasoning was noted as erroneous but the result stands
Whether prior appellate decisions (Williams v. White) require overruling	Coats relied on Williams; conflict existed with White	State: Williams incorrectly treated simultaneous possession as a single act	Held: Overrules Williams; follows White — simultaneous possession does not automatically equal a single act

People v. King, 66 Ill.2d 551 (Ill. 1977) (established one-act, one-crime rule: convictions cannot be based on precisely the same physical act)
People v. Rodriguez, 169 Ill.2d 183 (Ill. 1996) (one-act, one-crime two-step analysis: identify acts, then check lesser-included offenses)
People v. McLaurin, 184 Ill.2d 58 (Ill. 1998) (multiple convictions allowed when separate acts support distinct offenses)
People v. Williams, 302 Ill. App.3d 975 (Ill. App. 1999) (held simultaneous gun and drug possession was a single act; expressly overruled)
People v. White, 311 Ill. App.3d 374 (Ill. App. 2000) (held gun possession and drug possession can be separate acts; followed here)
People v. Artis, 232 Ill.2d 156 (Ill. 2009) (discusses integrity-of-process rationale for one-act, one-crime protection)
People v. Nunez, 236 Ill.2d 488 (Ill. 2010) (one-act, one-crime errors fall within second prong of plain-error review)
People v. Miller, 238 Ill.2d 161 (Ill. 2010) (use abstract-elements approach to determine lesser-included offenses in one-act, one-crime context)