People v. Anderson
2017 IL App (1st) 122640
| Ill. App. Ct. | 2017Background
- On March 5–6, 2003, two victims (Reynoso and Lilligren) were fatally shot while seated in a car behind Leader Liquors in Chicago; Officers Sedlacek and Park observed a man (defendant Robert Anderson) shooting into the vehicle and chased him.
- During the foot chase the shooter’s hood fell back and both officers saw his face from ~10–15 feet in a well‑lit alley; they separately identified Anderson about 15–20 minutes after the shooting.
- Officer Castillo, responding to radio broadcasts, encountered Anderson minutes later nearby; Castillo saw Anderson discard black gloves (later recovered) and a checkbook; the gloves tested positive for gunshot residue.
- A .40‑caliber handgun (with defaced serial number) was found on the roof of a garage along the route the shooter ran; ballistic testing matched cartridge cases and bullets from the victims to that gun.
- Defendant was convicted by a jury of two counts of first‑degree murder and sentenced to life imprisonment; he appealed raising eight claims (sufficiency, hearsay, cross‑examination limits, exclusion of prior acquittal evidence, denial of expert on eyewitness ID, denial of new trial based on newly discovered evidence, prosecutorial misconduct in closing, and ineffective assistance).
Issues
| Issue | Plaintiff's Argument (People) | Defendant's Argument (Anderson) | Held |
|---|---|---|---|
| Sufficiency of identification and evidence | Officer identifications were reliable; corroborated by flight, gloves with GSR, gun found on chase route, timing/location. | IDs were unreliable (short viewing, fixation on gun, officer uncertainty about name, lack of conclusive trace/DNA). | Conviction affirmed: Biggers factors support reliability; cumulative physical and circumstantial evidence overwhelmingly supports guilt. |
| Admission of Lorena Reynoso testimony (asserting defendant sought her brother) | Testimony was non‑hearsay (action: defendant asked whether Reynoso was home) and relevant to motive/context. | Testimony was hearsay and prejudicial (asserts victim’s fear of defendant). | Admission was within trial court discretion and not an abuse; testimony not hearsay as offered. |
| Limits on cross‑examination (race description and prior acquittal) | Limiting those specific lines did not impede meaningful cross‑examination; issues were collateral or irrelevant to bias. | Court improperly limited Sixth Amendment confrontation and impeachment (could have shown officer bias re: prior acquittal; impeach Park about race description). | No abuse of discretion: questioning was collateral/irrelevant or speculative; exclusion harmless given other evidence. |
| Denial of defense expert on eyewitness identification | Expert testimony unnecessary here because identification did not solely determine outcome; trial court properly balanced probative value vs prejudice. | Denial prevented expert evidence that could undermine eyewitness reliability (acquaintance ID issues); Lerma precedent requires admission in appropriate cases. | Denial not an abuse: case had strong corroborative physical/circumstantial evidence; even if error, it was harmless. |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (constitutional standard for sufficiency of the evidence) (establishes standard of review viewing evidence in light most favorable to the prosecution)
- Neil v. Biggers, 409 U.S. 188 (criteria for evaluating eyewitness identification reliability) (sets multi‑factor test used in Illinois)
- People v. Slim, 127 Ill.2d 302 (Illinois application that single witness ID can be sufficient) (applies Biggers factors in Illinois)
- People v. Caffey, 205 Ill.2d 52 (trial court discretion in evidentiary rulings) (discusses deference to trial court on admission of evidence and hearsay)
- Strickland v. Washington, 466 U.S. 668 (ineffective assistance standard) (two‑prong performance and prejudice test)
- People v. Blue, 205 Ill.2d 1 (harmless error test) (factors for determining whether an evidentiary error was harmless)