People v. Campbell

Procedural entryThis page is a short order in People v. Campbell. Read the opinion of the Court — 2023 IL App (1st) 220373
Appellate Court of Illinois·Decided May 8, 2026·No. 1-25-0788·Unpublished

Opinion

2026 IL App (1st) 250788-U No. 1-25-0788 Order filed May 8, 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. 15 CR 9396 ) DEANGELO CAMPBELL, ) Honorable ) Alfredo Maldonado, Defendant-Appellant. ) Judge, presiding.

JUSTICE HYMAN delivered the judgment of the court. Presiding Justice C.A. Walker and Justice Gamrath concurred in the judgment.

ORDER

¶1 Held: Defendant’s facial constitutional challenge to his conviction for aggravated unlawful use of a weapon fails under the Second Amendment of the United States Constitution and the test in New York State Rifle & Pistol Ass’n, Inc. v. Bruen, 597 U.S. 1 (2022) .

¶2 Deangelo Campbell appeals from the denial of his pro se petition for relief from judgment

filed under section 2-1401 of the Code of Civil Procedure (Code) (735 ILCS 5/2-1401 (West

2024)). He argues that the provision of the aggravated unlawful use of a weapon (AUUW) statute No. 1-25-0788

under which he was convicted is facially unconstitutional because it violates the second

amendment of the United States Constitution and the test set forth in New York State Rifle & Pistol

Ass’n, Inc. v. Bruen, 597 U.S. 1 (2022). We affirm.

¶3 Background

¶4 After a 2016 bench trial, Campbell was found guilty of AUUW predicated on possessing a

firearm without a valid Firearm Owner’s Identification (FOID) card and a concealed carry license

(CCL). See 720 ILCS 5/24-1.6(a)(1), (3)(A-5), (3)(C) (West 2014). Evidence reflected that officers

saw Campbell retrieve a firearm from his waistband and throw it into a car. A certification from

the Illinois State Police Department established that Campbell did not have a valid FOID card or

CCL at the time of the offense. Campbell was sentenced to one year in prison. We affirmed on

direct appeal. See People v. Campbell, 2019 IL App (1st) 161640.

¶5 In 2024, Campbell filed a pro se section 2-1401 petition alleging that his AUUW

conviction should be vacated under People v. Aguilar, 2013 IL 112116. The circuit court denied

relief, stating that Campbell’s case was not an “Aguilar issue.”

¶6 Analysis

¶7 Campbell argues that the provision of the AUUW statute under which he was convicted is

facially unconstitutional under the Second Amendment and Bruen.

¶8 As a threshold matter, Campbell failed to raise the facial Bruen challenge in the circuit

court. Ordinarily, a defendant “who fails to raise an issue before the trial court forfeits the issue”

on appeal. People v. Rodriguez, 2021 IL App (1st) 200173, ¶ 58. But, “[w]hen a statute is declared

facially unconstitutional and void ab initio, it means that the statute was constitutionally infirm

from the moment of its enactment and, therefore, unenforceable.” People v. Thompson, 2015 IL

-2- No. 1-25-0788

118151, ¶ 32. Moreover, “a judgment based on a statute that is facially unconstitutional is void,”

and challenges based on a void statute are “not subject to forfeiture” or “any other ordinary

procedural bar.” In re N.G., 2018 IL 121939, ¶¶ 43, 57.

¶9 This is so even when a defendant raises a facial challenge for the first time on appeal from

the denial of a section 2-1401 petition that raised different claims, as Campbell did. See People v.

Doehring, 2024 IL App (1st) 230384, ¶ 14 (permitting facial Bruen challenge for first time on

appeal from denial of section 2-1401 petition); see also People v. McTizic, 2025 IL App (1st)

240467-U, ¶ 5 (same). Therefore, Campbell may raise the facial Bruen challenge.

¶ 10 A presumption exists that all statutes are constitutional, and a defendant carries a “heavy

burden” in rebutting that presumption by “clearly establish[ing] that [the statute] violates the

constitution.” (Internal quotation marks omitted.) People v. Rizzo, 2016 IL 118599, ¶ 23. Courts

have a duty to uphold the constitutionality of a statute whenever possible, “resolving any doubts

in favor of the statute’s validity.” Id. A facial challenge requires a showing that “the statute is

unconstitutional under any set of facts, i.e., the specific facts related to the challenging party are

irrelevant.” Id. ¶ 24. If a situation exists in which the statute can be validly applied, a facial

challenge fails. Id. We review a statute’s constitutionality de novo. Id. ¶ 23.

¶ 11 AUUW Statute and Bruen Decision

¶ 12 Campbell was convicted of violating section 24-1.6(a)(1), (3)(A-5), (3)(C) of the AUUW

statute, which provides that “[a] person commits the offense of aggravated unlawful use of a

weapon when he or she knowingly carries on or about his or her person *** any pistol, revolver,

*** or other firearm” without a “currently valid license under the Firearm Concealed Carry Act”

and “a currently valid [FOID] Card.” 720 ILCS 5/24-1.6(a)(1), (3)(A-5), (3)(C) (West 2014).

-3- No. 1-25-0788

¶ 13 The FOID Card Act provides that “no person may acquire or possess any firearm ***

within this State without *** a [FOID] card previously issued *** by the Department of State

Police.” 430 ILCS 65/2(a)(1) (West 2014). The FOID card application must include evidence that

an applicant, among other things, (i) is an Illinois resident, (ii) is at least 21 years of age, (iii) has

not been convicted of a felony, (iv) has not been a patient in a mental health facility in the five

years preceding the application or suffers from an intellectual disability, (v) is not subject to an

order prohibiting the possession of a firearm, and (vi) has not been convicted of battery, assault,

aggravated assault, or other similar offense where a firearm was used or convicted of domestic

battery, aggravated domestic battery, or a similar offense. Id. § 65/4(a)(2).

¶ 14 The Firearm Concealed Carry Act mandates that an individual shall be issued a CCL if (i)

the individual completes an application and provides the information and documents require; (ii)

is at least 21 years old, (3) has been issued a currently valid FOID card, (iv) has not been convicted

of an offense involving the threat of force or violence or alcohol or drugs within five years of the

application, (v) is not the subject of a pending warrant or prosecution, (vi) has not been subject to

court-ordered alcohol or drug treatment, (vii) has completed firearms training and education, (viii)

paid the fees, and (ix) does not pose a danger to themselves or others. 430 ILCS 66/10(a), 25, 30

(West 2014). An individual must possess the CCL “at all times the licensee carries a concealed

firearm,” absent certain exceptions. Id. § 66/10(g).

¶ 15 The second amendment to the United States Constitution provides that “[a] well regulated

Free access — add to your briefcase to read the full text and ask questions with AI

People v. Campbell, (Ill. Ct. App. 2026).

People v. Campbell (People v. Campbell) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

District of Columbia v. Heller
554 U.S. 570 (Supreme Court, 2008)
McDonald v. City of Chicago
561 U.S. 742 (Supreme Court, 2010)
People v. Aguilar
2013 IL 112116 (Illinois Supreme Court, 2013)
People v. Rizzo
2016 IL 118599 (Illinois Supreme Court, 2016)
In re N.G.
2018 IL 121939 (Illinois Supreme Court, 2018)
People v. Campbell
2019 IL App (1st) 161640 (Appellate Court of Illinois, 2019)
Yakich v. Aulds
2019 IL 123667 (Illinois Supreme Court, 2019)
People v. Rodriguez
2021 IL App (1st) 200173 (Appellate Court of Illinois, 2021)
People v. McTizic
2025 IL App (1st) 240467-U (Appellate Court of Illinois, 2025)
People v. Thompson
2025 IL 129965 (Illinois Supreme Court, 2025)
People v. Wright
2025 IL App (1st) 241047-U (Appellate Court of Illinois, 2025)
People v. Torres
2025 IL App (1st) 232253-U (Appellate Court of Illinois, 2025)