Additionally, at least one state has applied similar reasoning in finding robbery to be a continuing offense when elements of the crime are committed in more than one jurisdiction. People v. Kalwa, 306 Ill.App.3d 601, 239 Ill.Dec. 726, 714 N.E.2d 1023 (1999) (robbery takes on the nature of a continuing offense when the elements of the crime occur sequentially). "A substantial majority of the states today have statutes that adopt an interpretation of the territorial principle substantially more expansive than the traditional common law position."

Indeed, the dissent reasoned, because the expert had found defendant fit, the trial court could have properly declined to hold a hearing, particularly after the defense motion was withdrawn. See People v. Kalwa, 306 Ill. App. 3d 601, 603 (1999). This court allowed the State's timely petition for leave to appeal.

¶ 13 When denying the defendant's motion to dismiss count I, the trial court agreed that regardless of where the defendant had actually affixed the Mercury's plate to the Durango, the charged offense was consummated in Johnson County, where her intent to use the plate to steal gasoline without being apprehended was realized. See People v. Kalwa, 306 Ill. App. 3d 601, 614 (1999) ("If a crime is partly committed in one county and partly in another, venue is proper in either county."). ¶ 14 In June 2015, the cause proceeded to a stipulated bench trial, where the parties submitted an agreed written summary of the relevant facts of the case.

Accordingly, the court did not abuse its discretion in failing to hold a fitness hearing. As succinctly stated in People v. Kalwa, 306 Ill. App. 3d 601, 613, 714 N.E.2d 1023, 1031 (1999): "It is well settled in Illinois that where no bona fide doubt as to a defendant's competency to stand trial exists, a psychiatric report shows defendant fit and the defendant moves for or acquiesces in the withdrawal of a petition requesting a fitness hearing, there is no abuse of discretion where the court fails to hold a fitness hearing sua sponte.

A defendant who is denied his right to a fitness hearing is not automatically entitled to a new trial if evidence presented to the trial court in a posttrial proceeding establishes that the defendant did not suffer impairment as a result of his ingestion of psychotropic medication. Kinkead II, 182 Ill.2d at 338-40, citing People v. Cortes, 181 Ill.2d 249 (1998), People v. Neal, 179 Ill.2d 541 (1997), and People v. Burgess, 176 Ill.2d 289 (1997); see also People v. Kalwa, No. 1-97-1671 (June 30, 1999); People v. Mayoral, 299 Ill. App.3d 899 (1998); People v. Hill, 297 Ill. App.3d 500 (1998). In the present case, the record does not establish that defendant actually was taking psychotropic medication at the time of his trial.