Legally Inconsistent Convictions for Murder and Involuntary Manslaughter
In People v. O'Neil, 194 Ill. App. 3d 79, 550 N.E.2d 1090, 141 Ill. Dec. 44 (1990), three individual defendants were convicted of the murder of a coworker and two corporate defendants were convicted of the involuntary manslaughter of the same coworker. O'Neil, 194 Ill. App. 3d at 80-81.
On appeal, the defendants argued that the judgments for murder and involuntary manslaughter were inconsistent because the offense of murder requires a knowing and intentional act while reckless conduct does not. O'Neil, 194 Ill. App. 3d at 84.
The defendants further argued that both convictions arose from the same acts of the individual defendants. O'Neil, 194 Ill. App. 3d at 84.
The O'Neil court held that the judgments rendered for the offenses were legally inconsistent because the same conduct was used to support both offenses which had mutually exclusive mental states. O'Neil, 194 Ill. App. 3d at 96.