People v. Adams

Before us are two criminal cases we have consolidated for review, People v. Adams, No. 75111, and People v. Valdez, No. 75654. Although these cases involve wholly unrelated facts, they share a common feature. In both cases the appellate court reversed the defendants’ convictions on the grounds that the State had failed to prove venue beyond a reasonable doubt.

We granted the State leave to appeal in each case. (134 Ill. 2d R. 315.) For the reasons that follow, we agree with the appellate court’s conclusion that venue is a material allegation that must be proved by the State beyond a reasonable…