People v. Anderson
407 Ill. App. 3d 662
| Ill. App. Ct. | 2011Background
- Anderson was charged with a single count of residential burglary in Blue Island, Illinois, for entering the Hess residence on September 17, 2005, with intent to commit theft.
- Evidence showed Anderson initially acted as a lookout for Cat Daddy, then entered the Hess home and was found in possession of keys from the residence.
- Anderson gave a custodial statement to police after mirandized interrogation; he later claimed illness and insulin needs that allegedly were not tended to during custody.
- Defense challenged admission of a statement as voluntary, suppression of the statement, and the use of a prior conviction copy with surplusage to impeach credibility.
- The trial court denied suppression, admitted a certified copy of a prior conviction with accompanying details, and permitted the jury to hear an accountability theory and other related evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Denial of suppression motion | People argued the confession was voluntary and properly admitted. | Anderson contends the confession was involuntary due to illness/denied medical needs. | Denied; confession valid under totality of circumstances. |
| Uncharged offense / accountability | State contends the two Hess entries were a single continuous burglary. | Bell-based argument that separate offenses could be considered; risks of invalid theory. | Harmless beyond a reasonable doubt; valid under harmless-error analysis. |
| Admission of certified copy with surplusage | Prior-conviction copy admissible to impeach crediblity. | Surplusage and sentencing details should be deleted; error not preserved. | No reversible error; evidence not closely balanced to merit relief. |
| Hearsay and defense testimony | Testimony about instructions to go to Hess residence did not violate hearsay rules. | Excluded testimony was necessary to explain his actions and defense. | Exclusion not reversible; testimony would not have changed outcome given overwhelming evidence. |
| Voir dire on prior conviction bias | Rule 431(a) prohibits voir dire on law/instructions issues; questioning prior conviction effects is improper. | Jury bias could be revealed by questioning about prior conviction. | Trial court did not abuse discretion; Rule 431(a) barred such questioning. |
Key Cases Cited
- People v. Gorgis, 337 Ill.App.3d 960 (2003) (totality-of-the-circumstances standard for voluntariness)
- People v. Davis, 54 Ill.App.3d 517 (1977) (admission of prior-conviction copy; surplusage concerns)
- People v. Naylor, 229 Ill.2d 584 (2008) (plain-error analysis for admissibility of prior conviction)
- People v. Brandon, 157 Ill.App.3d 835 (1987) (voir dire limitation on questioning regarding prior convictions)
- People v. Strickland, 129 Ill.2d 550 (1989) (credibility and police testimony evaluation in suppression context)