Background
Antonio D. Watson pleaded guilty in 2021 to unlawful possession of a weapon by a felon, a Class 2 felony, arising from his possession of a firearm on October 20, 2019. Days later, the State added an armed habitual criminal charge, a Class X felony, based on the same firearm possession but alleging additional qualifying convictions. A jury later found Watson guilty of armed habitual criminal.
In 2024, Watson and the State entered a negotiated sentencing agreement. Watson received concurrent sentences of 10 years on the weapon-by-a-felon count and 8 years on the armed-habitual-criminal count; the State dismissed an aggravated-battery-with-a-firearm charge, and Watson agreed to abandon his pending challenges. On appeal, Watson argued that the later-added charge violated double jeopardy and that the two convictions violated Illinois’s one-act, one-crime rule.
The Court’s Holding
The court held that Watson could not pursue his double-jeopardy challenge to the armed-habitual-criminal conviction while retaining the benefits of the negotiated sentencing agreement. The agreement incorporated his earlier guilty plea and included dismissal of the remaining Class X charge. Watson neither sought to vacate the agreement nor claimed that he entered it unknowingly, unintelligently, or involuntarily.
The State conceded, however, that both firearm convictions rested on the same physical act: Watson’s possession of a firearm on October 20, 2019. The court accepted that concession and held that the one-act, one-crime rule required vacatur of the less serious offense. It vacated Watson’s Class 2 unlawful-possession-of-a-weapon-by-a-felon conviction and sentence, while affirming the armed-habitual-criminal conviction and the remainder of the judgment.
Key Takeaways
- A defendant generally cannot attack an integral part of a negotiated sentencing agreement while keeping the agreement’s benefits.
- Two convictions based on the same single act of firearm possession violated the one-act, one-crime rule here.
- The Class 2 weapon-by-a-felon conviction was vacated because it was less serious than the Class X armed-habitual-criminal conviction.
Why It Matters
The decision illustrates the limits of appellate challenges after a negotiated criminal disposition: a defendant seeking to undo a bargained-for conviction or sentence ordinarily must seek to unwind the agreement as a whole. But it also confirms that the parties may jointly correct a one-act, one-crime error, including through the State’s confession of error.