People v. McLaurin, 2020 IL 124563

On May 25, 2014, Officer Nicheloe Fraction observed Jasper McLaurin leave an apartment building carrying a silver/ chrome handgun about 50 feet away and with an unobstructed view; McLaurin crossed the street and entered the rear of a white van.
Fraction called for backup, followed the van, and confirmed after the stop that the van and occupant matched what she had seen; she later identified a recovered gun as the same color and size as the one she saw.
Officer Jesse Rodriguez searched the stopped van, saw a loaded 9mm chrome handgun underneath (near the rear passenger side where McLaurin exited), cleared and inventoried it; the gun was not offered into evidence and no fingerprint testing was done.
It was stipulated McLaurin was on mandatory supervised release, lacked a FOID card, and had prior qualifying convictions, supporting the armed habitual criminal charge.
After a bench trial the circuit court convicted McLaurin of being an armed habitual criminal and sentenced him to seven years; the appellate court reversed, entering acquittal for insufficient proof that the item observed met the statutory definition of a firearm.
The Illinois Supreme Court granted review and reversed the appellate court, holding the eyewitness testimony plus corroboration could permit a rational factfinder to find beyond a reasonable doubt that McLaurin possessed a firearm as defined by the FOID Act.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the State proved beyond a reasonable doubt that McLaurin possessed a "firearm" as defined by the FOID Act	Fraction’s unimpeached eyewitness testimony that she saw McLaurin carrying a silver handgun at close range, corroborated by recovery of a loaded 9mm chrome handgun matching her description	Fraction’s description lacked detail (no make/model, mechanism), weapon not introduced or fingerprinted, so the State failed to prove the item met the statutory definition	Reversed appellate court; viewing evidence in State’s favor, a rational trier of fact could infer the item was a firearm under FOID Act and convict McLaurin

People v. Washington, 2012 IL 107993 (Ill. 2012) (unequivocal eyewitness testimony under good viewing conditions can support inference that defendant possessed a real gun)
People v. Wright, 2017 IL 119561 (Ill. 2017) (applied Washington; victims’ positive identifications supported finding of firearm possession)
People v. Ross, 229 Ill. 2d 255 (Ill. 2008) (evidence insufficient where the item proven was a BB gun and did not meet the statutory dangerousness/firearm standard)
People v. Cunningham, 212 Ill. 2d 274 (Ill. 2004) (adopts Jackson standard for sufficiency-of-the-evidence review)
Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (standard: evidence viewed in light most favorable to prosecution must allow any rational trier of fact to find every element beyond a reasonable doubt)