People v. Lowe, 205 N.E.3d 139

Defendant Artaveus Lowe was indicted under 720 ILCS 5/11-9.3(a) for being a registered child sex offender "present upon school property" while minors were present.
On Oct. 14, 2018 a nonschool cheerleading competition for middle-school-age children was held inside the Dundee-Crown High School field house; minors were arriving when Lowe parked in a handicapped space directly in front of the field house.
An off-duty police officer recognized Lowe as a registered child sex offender; witnesses (including a coach and a detective familiar with the campus) identified the location as Dundee-Crown High School or its campus; a photo showed the field house with school signage.
Defense moved for a directed finding, arguing the State failed to prove the parking lot was "real property comprising" the school; the trial court denied the motion, found Lowe guilty, and sentenced him to one year.
On appeal Lowe argued the State presented no evidence that the field house parking space was part of the high school grounds and relied on out-of-state cases limiting "comprising" to contiguous, commonly owned tracts; the State contended the lot was plainly school grounds and that reading otherwise would create an absurd loophole.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the parking space in front of the field house was "real property comprising [a] school" under § 11-9.3(a), so that presence there while minors were present violated the statute	The parking area was part of the high school campus/grounds; the statute's plain meaning and purpose include school grounds and adjacent facilities, so the lot falls within "real property comprising any school"	The State failed to prove the parking lot was part of the school property (ownership/contiguity); the term "comprising" requires evidence the tract is part of the school's real property (relied on Stamps and Peterson)	Court rejected the narrow building-only view; held the field house and its immediate parking area were part of the school grounds under the Code and statute purpose, so evidence was sufficient and conviction affirmed

Jackson v. Virginia, 443 U.S. 307 (1979) (standard for reviewing sufficiency of the evidence)
People v. Collins, 106 Ill.2d 237 (1985) (Illinois adoption of Jackson sufficiency standard)
People v. Davison, 233 Ill.2d 30 (2009) (reviewing court must draw all reasonable inferences for prosecution)
Stamps v. State, 620 So.2d 1033 (Fla. Dist. Ct. App. 1993) (defendant relied on this case to argue remote overflow parking lots do not "comprise" a school)
State v. Peterson, 490 N.W.2d 53 (Iowa 1992) (discusses "real property comprising a school" as including contiguous land surrounding school buildings)