People v. Breseman
2025 IL App (1st) 232362-U
Ill. App. Ct.2025Background
- John Breseman was convicted of first-degree murder for shooting and killing Christina Czuj following an altercation in his vehicle in the early hours of January 1, 2021.
- Breseman and Czuj had a volatile, tumultuous relationship, with evidence of Breseman’s obsessive behavior, including repeated blocked phone calls and stalking-like conduct.
- On the night of the incident, the two had been drinking, and Czuj was reportedly intoxicated; after leaving a bar, an altercation occurred inside Breseman’s truck, leading to Czuj’s death.
- During trial, the prosecution introduced witness testimony characterizing Breseman as Czuj’s “stalker,” and presented evidence of the strained relationship as motive.
- The defense asserted self-defense and challenged: (1) the refusal of a jury instruction related to potentially exculpatory evidence (the failure to test a substance on Czuj’s face), and (2) the admission of testimony labeling him a “stalker.”
Issues
| Issue | Breseman’s Argument | State’s Argument | Held |
|---|---|---|---|
| Refusal to give non-pattern jury instruction re: evidence | Jury should be told failure to test substance allows inference against the State | No duty to test every stain; no evidence this was exculpatory or significant | No abuse of discretion; any error was harmless |
| Admitting "stalker" testimony from two witnesses | Prejudicial and misleading; labels him the aggressor | Relevant to show motive, relationship, and context for jury | Properly admitted; not unduly prejudicial |
Key Cases Cited
- People v. Bannister, 232 Ill. 2d 52 (jury instructions must provide correct legal principles to the jury)
- People v. Danielly, 274 Ill. App. 3d 358 (non-IPI instruction appropriate where lost evidence is critical to defense)
- Arizona v. Youngblood, 488 U.S. 51 (no due process violation from lost evidence absent bad faith by police)
- People v. Robinson, 189 Ill. App. 3d 323 (evidence of motive generally admissible in homicide cases)
