People v. Curtis

Defendant Timothy Curtis was charged with three counts of aggravated battery. Following a jury trial, Curtis was found guilty of two counts and sentenced to concurrent three-year terms of imprisonment. He appealed, claiming that his due process rights were violated when he was required to wear a stun belt without the required hearing and that his convictions violated one-act, one-crime principles. We find that Curtis waived the due process issue by failing to object to the use of restraints and that one of his convictions must be vacated pursuant to one-act, one-crime principles. Accordingly,…