People v. Bonds
2025 IL App (1st) 231439-U
Ill. App. Ct.2025Background
- Angelo Bonds was charged with aggravated robbery, robbery, and retail theft stemming from two incidents at a Target store in Chicago (June 27 and July 23, 2022).
- Bonds was identified as a repeat offender who frequently stole liquor from the store.
- On June 27, 2022, Bonds placed liquor bottles in a bag and, when confronted by a security manager (Vergara), brandished a metal object and said, "If you want your liquor, get closer."
- Vergara believed the metal object to be a possible knife and disengaged due to fear for his safety, allowing Bonds to leave with the liquor.
- Bonds was later apprehended during a subsequent theft on July 23, 2022; he admitted to taking liquor to support his drug habit.
- After a bench trial, Bonds was found guilty of robbery and two counts of retail theft, but acquitted of aggravated robbery. He received concurrent sentences.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence for robbery | Bonds threatened imminent force, causing fear | Single statement was not a true threat | Evidence was sufficient to find robbery conviction |
| Nature of threat and use of force | Words and brandishing object reasonably induced fear | No substantial threat or force was used | Threat reasonable; victim's fear was justified |
| Witness credibility and surveillance | Vergara's testimony was credible | Vergara's account was speculative, footage unclear | Court credited witness, found facts supported state |
| Weapon presence as element | Actual weapon not required, only reasonable threat | No proof object was weapon, thus no threat | Presence of weapon not required for robbery |
Key Cases Cited
- In re Winship, 397 U.S. 358 (1970) (state must prove guilt beyond a reasonable doubt)
- Jackson v. Virginia, 443 U.S. 307 (1979) (sufficiency of evidence standard)
- People v. Dennis, 181 Ill. 2d 87 (1998) (robbery requires reasonable fear of violence)
- People v. Carpenter, 71 Ill. App. 2d 137 (1966) (fear of violence justifies victim relinquishing property)
- People v. Cooksey, 309 Ill. App. 3d 839 (1999) (brandishing weapon during theft constitutes force for robbery)