People v. Bobo

── People v. Bobo ── Court: Appellate Court of Illinois Date: April 17, 2026 Category: General 2026 IL App (1st) 241638-U No. 1-24-1638 Order filed April 17, 2026 Sixth Division NOTICE: This order was filed under Supreme Court Rule 23 and is not precedent except in the limited circumstances allowed under Rule 23(e)(1). ______________________________________________________________________________ IN THE APPELLATE COURT OF ILLINOIS FIRST DISTRICT ______________________________________________________________________________ THE PEOPLE OF THE STATE OF ILLINOIS, ) Appeal from the ) Circuit Court of Plaintiff-Appellee, ) Cook County. ) v. ) No. 23 MC5 001175 ) ZYKIA BOBO, ) Honorable ) John A. Fairman, Defendant-Appellant. ) Judge, presiding. JUSTICE GAMRATH delivered the judgment of the court. Presiding Justice C.A. Walker and Justice Pucinski concurred in the judgment. ORDER ¶1 Held: We affirm defendant’s conviction for unlawful use of a weapon where the State proved knowing possession of a firearm beyond a reasonable doubt and the statute is constitutional. ¶2 After a bench trial, defendant Zykia Bobo was convicted of misdemeanor unlawful use of a weapon (UUW) and sentenced to one year of conditional discharge along with 100 hours of community service. On appeal, Bobo contends the evidence was insufficient to prove beyond a reasonable doubt that she knowingly possessed a firearm, and the statutory provision under which No. 1-24-1638 she was convicted is unconstitutional both on its face and as applied, citing New York State Rifle & Pistol Ass’n v. Bruen, 597 U.S. 1 (2022), the second amendment of the United States Constitution (U.S. Const., amend. II), and the Illinois Constitution (Ill. Const. 1970, art. I, § 22). We find these arguments unpersuasive and therefore affirm. ¶3 Bobo was charged with UUW (720 ILCS 5/24-1(a)(4)(iv) (West 2022)) after a loaded gun was found in her diaper bag at the Bridgeview courthouse security checkpoint on February 24, 2023. At trial, the evidence showed Bobo admitted to the sheriff’s deputy that she owned the diaper bag and the gun. She said she primarily kept the firearm in the diaper bag and either forgot or was unaware it was in the bag. The State published footage from a deputy’s body-worn camera, showing Bobo’s bag with the firearm inside passing through the security conveyor belt. When asked about the gun, Boho said the gun stays in the bag for the most part. ¶4 The State entered into evidence two documents from the Illinois State Police Firearms Services Bureau: (1) a certified abstract of Bobo’s FOID card history showing that her FOID registration was active as of May 8, 2018, and current through May 8, 2028, and (2) a certified abstract showing no record on file for Bobo having a concealed carry license (CCL). ¶5 Defense counsel moved for a directed finding, arguing: “[T]his is not a strict liability offense. This offense is not about an act[;] this is about mens rea. Mens rea is knowledge. And even in the light most favorable to the State there has been no evidence to support proof beyond a reasonable doubt that my client had any knowledge of that weapon being