People v. Blankenship, 943 N.E.2d 1111

No. 2-08-1012, People v. Blankenship, appellate decision from Illinois Second District; conviction for possession of a controlled substance (720 ILCS 570/402).
Defendant challenged Rule 431(b) jury-questioning, chain of custody, and a $10 street-value fine.
Trial court instructed jurors on Zehr principles and asked if they accepted them; defendant argued separate understanding was required.
State offered witnesses (Veruchi, Rossow, Shively-Earl) to prove a cocaine exhibit; defense questioned the chain of custody.
Court admitted the exhibit; defendant moved to supplement the record with police reports; ruling on admissibility preserved on appeal.
Sentencing included a $10 street-value fine supported by statutory framework; defendant preserved only via plain-error arguments, which court declined to reach.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Rule 431(b) compliance	Blankenship	Blankenship	No error; proper acceptance of Zehr principles by jurors
Chain of custody	State proved custody via descriptions and lab testing	Missing link between Veruchi and Bond; potential tampering	Prima facie custody established; no reversible error; matching descriptions sufficient
Street-value fine	$10 based on seizure value; evidentiary basis	Not preserved; possible plain error	Validly imposed; no plain-error

People v. Woods, 214 Ill. 2d 455 (2005) (chain-of-custody requires showing reasonable measures to protect evidence)
People v. Pettis, 184 Ill. App. 3d 743 (1989) (matching description supports chain where link missing)
People v. Johnson, 361 Ill. App. 3d 430 (2005) (one unique identifier can substitute for missing links in custody)
Howard, 387 Ill. App. 3d 997 (2009) ( weighs burden shift and uniqueness of markings in chain of custody)
Calabrese, 398 Ill. App. 3d 98 (2010) (Rule 431(b) analysis—acceptance suffices when jurors understand and accept)
Garth, 353 Ill. App. 3d 108 (2004) (foundation requirement for admission of physical evidence)