People v. Belknap, 2014 IL 117094

Background

Defendant Daniel Belknap was convicted of first‑degree murder for the 2006 death of five‑year‑old Silven Yocum and sentenced to 24 years; this was his second trial after a prior reversal for a Rule 431(b) voir dire error.
Medical testimony established Silven died from multiple blunt‑force head traumas sustained about 12–24 hours before her seizures; injuries could have been inflicted by a person or a medium cylindrical object.
Only three people were with Silven during the relevant period: Belknap, mother Erin Yocum, and Erin’s brother Erik; Belknap admitted methamphetamine use and sleep deprivation during that time.
Two jailhouse informants testified that Belknap confessed in jail to striking Silven during a meth‑induced rage; their testimony was consistent but required cautious weight.
Trial counsel did not object to the trial court’s voir dire wording (it asked jurors whether they disagreed with or accepted Rule 431(b) principles but did not ask whether they understood them), nor to certain prosecutor remarks; Belknap raised insufficient‑evidence and plain‑error arguments on appeal.
The appellate court reversed under the plain‑error closely‑balanced prong; the Illinois Supreme Court granted review and reversed the appellate court, holding the evidence was not closely balanced and the conviction was supported by sufficient evidence.

Issues

Issue	State's Argument	Belknap's Argument	Held
Trial court compliance with Ill. S. Ct. R. 431(b) (voir dire)	Trial court erred by not asking jurors if they understood the Rule 431(b) principles; error conceded.	Same — court failed to ask jurors whether they understood the four Rule 431(b) principles.	Court: Failure to ask whether jurors understood the principles is error (Rule requires "understands and accepts"). Error was forfeited (no objection), so plain‑error review applies.
Plain‑error review — closely balanced evidence prong	Appellate court erred by isolating portions of the State’s evidence; a commonsense, contextual review shows the evidence was not closely balanced.	Evidence was closely balanced (no eyewitnesses, no direct physical link; conviction rested mainly on jailhouse informants), so plain error warranted reversal.	Court: Evidence was not closely balanced after contextual commonsense review; appellate court erred to reverse under first prong of plain error.
Sufficiency of the evidence	Evidence (circumstantial plus jailhouse confessions and defendant’s behavior) sufficed to support conviction beyond a reasonable doubt.	Evidence insufficient — primarily jailhouse informant testimony and circumstantial material.	Court: Viewing evidence in the light most favorable to the State, a rational trier of fact could find guilt beyond a reasonable doubt; conviction affirmed.
Prosecutor's alleged inflammatory remarks	N/A (State did not contest)	Remarks appealed under plain error (not preserved); argued they were improper and prejudicial.	Court: Issue forfeited and because evidence was not closely balanced, no plain‑error reversal; court did not decide whether remarks were improper.

Key Cases Cited

People v. Thompson, 238 Ill. 2d 598 (2010) (Rule 431(b) violations are not structural per se and failure to ask both "understand" and "accept" is error but not automatic reversible error).
People v. Piatkowski, 225 Ill. 2d 551 (2007) (explaining two prongs of plain‑error review for forfeited errors).
People v. Zehr, 103 Ill. 2d 472 (1984) (emphasizing the importance of voir dire questions to secure a fair, impartial jury).
People v. Manning, 182 Ill. 2d 193 (1998) (credibility of informants is for the jury; informant testimony not inherently unbelievable).
People v. Collins, 106 Ill. 2d 237 (1985) (standard for sufficiency review—Jackson v. Virginia test).
People v. Herron, 215 Ill. 2d 167 (2005) (plain‑error framework and need for commonsense contextual evidence assessment).
Enoch v. People, 122 Ill. 2d 176 (1988) (failure to raise an issue at trial constitutes forfeiture).
Jackson v. Virginia, 443 U.S. 307 (1979) (establishing the standard of review for sufficiency of the evidence).