People v. Amigon
239 Ill. 2d 71
| Ill. | 2010Background
- Defendant Rene Amigon was convicted of first degree murder and two counts of aggravated battery with a firearm for a 1995 shooting; he was serving consecutive sentences when a victim died years later and a new murder charge was brought.
- Dr. Nancy Jones, the Cook County assistant medical examiner, testified that pneumonia caused Ruiz’s death and linked it to the gunshot-induced quadriplegia.
- Ruiz, paralyzed by the 1995 gunshot, survived for about five years before dying of community-acquired pneumonia.
- Autopsy evidence tied Ruiz’s pneumonia and death to his quadriplegia and to the gunshot injury’s impact on lung function and immune status.
- The defense challenged (a) the sufficiency of causation evidence for proximate cause and (b) the admissibility of the 1995 custodial statement under the electronic recording statute.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Proximate cause proof for Ruiz’s death | Collins: State proven causation beyond reasonable doubt | Amigon argues causation lacked factual basis and testimony was speculative | Prosecution evidence sufficient; reasonable jury could find causation. |
| Retroactivity of electronic recording statute | State argues statute not retroactive; not applicable to this statement | Amigon contends retroactive exclusion of statement | Statute not applied retroactively; custodial statement admitted. |
Key Cases Cited
- People v. Collins, 106 Ill.2d 237 (Ill. 1985) (standard for reviewing sufficiency of evidence; jus asking whether any reasonable trier could find guilt beyond a reasonable doubt)
- People v. Brackett, 117 Ill.2d 170 (Ill. 1987) (causation testimony must have factual basis; autopsy-based causation supported here)
- Gulliford v. City of Chicago, 86 Ill.App.3d 237 (Ill. App. 1980) (foreseeability in murder charges where death occurs after injury)
- Reader v. People, 26 Ill.2d 210 (Ill. 1962) (early foreseeability and causation standards in murder cases)
- Carrillo v. People, 164 Ill.2d 144 (Ill. 1995) (long intervals between injury and death do not bar murder charges)
- People v. Slywka, 365 Ill.App.3d 34 (Ill. App. 2006) (long-interval recoveries; causation in murder context)
- People v. Buck, 361 Ill.App.3d 923 (Ill. App. 2005) (retroactivity considerations under section 103-2.1(b))
- People v. Armstrong, 395 Ill.App.3d 606 (Ill. App. 2009) (retroactivity of electronic recording statute; hospital treatment context)
- People v. Brown, 225 Ill.2d 188 (Ill. 2007) (statutory interpretation; intent of legislature in retroactivity)