In the case of Judge Andersen, he has accepted stolen property from his wife, Illinois Appellate Judge Sheila M. O'Brien.

Just as a person who is in possession of property which has been stolen is not the legal owner of the property, a person who is in possession of "ill-gotten" gains is not the legal owner of those "ill-gotten" gains. The stolen property must be returned to the legal owner; the "ill-gotten" gains should be returned to the legal owner.

The title to personal property requires a chain of proof as does the title to real property.

In criminal law the hardest case for a defense attorney that he must contend with, is a case where the client, the defendant, is accused of being "in possession of stolen property". In such a case the only valid defense is proof of ownership of the goods in question. The burden is on the party who may have "ill-gotten gains" in their possession to prove that they have not received any "ill-gotten gains".

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