People v. Harris, 966 N.E.2d 496

Harris charged with four counts of aggravated unlawful use of a weapon (AUUW) with counts I–IV detailing vehicle carry, FOID status, and on-or-about-person delivery.
Police recovered a .45-caliber handgun from the closed center console of Harris's car after consented search at the scene of a shooting.
Trial court convicted counts I, III, and IV and acquitted count II; suppression motion denied.
An anonymous eyewitness statement to Officer Combs regarding Harris retrieving a weapon from his car was admitted.
State conceded acquittal on count II for FOID issue and required reversal of count IV; issues on sufficiency and corpus delicti were raised.
Appellate court reversed counts I, III, IV and vacated the $5 court system fee; count II remained acquitted.

Issue	Plaintiff's Argument	Defendant's Argument	Held
FOID issue on count IV	Harris lacked valid FOID at time	Harris had valid FOID	Count IV vacated
Whether center-console encasing defeats count I	Gun was uncased; unconcealed	Gun encased in console	Count I vacated
Corpus delicti for count III	Corroborating evidence sufficient	Hearsay corroboration insufficient	Count III vacated
AUUW constitutional challenge	AUUW constitutional	Not argued now	Not considered on this appeal
Court system fee under 55 ILCS 5/5-1101	Fee valid	Fee not applicable	$5 fee vacated

People v. Holmes, 241 Ill. 2d 509 (Ill. 2011) (center-console as a case under AUUW)
People v. Diggins, 235 Ill. 2d 48 (Ill. 2009) (center console treated as case)
People v. Sargent, 239 Ill. 2d 166 (Ill. 2010) (corpus delicti and corroboration rule)
People v. Lesure, 271 Ill.App.3d 679 (1st Dist. 1995) (hearsay corroboration insufficient)
People v. Anderson, 42 Ill.App.3d 1040 (1st Dist. 1976) (extrinsic corroboration of confession)
People v. Banks, 378 Ill.App.3d 856 (1st Dist. 2007) (hearsay evidence admitted without objection probative value)