People v. Cisneros
996 N.E.2d 163
Ill. App. Ct.2013Background
- Cisneros was convicted by jury of aggravated battery causing great bodily harm arising from stabbing Gomez on June 3, 2011.
- The State charged two counts: count I for knowingly causing great bodily harm and count II for using a deadly weapon to knowingly cause bodily harm.
- Gomez suffered five lacerations, with a blood-soaked shirt; he received stitches to the hand and back and later showed scars to the jury.
- Medical testimony described multiple lacerations and a neck wound; photographs and physical evidence supported injuries, though some descriptions differed.
- Cisneros challenged the sufficiency of evidence for great bodily harm; the trial court denied posttrial relief, and the conviction was affirmed on appeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did the State prove great bodily harm beyond a reasonable doubt? | Cisneros argued injuries were only ordinary bodily harm lacking gravity. | Cisneros contended wounds were not grave and did not exceed ordinary bodily harm as defined by case law. | Yes; a rational jury could find great bodily harm from the injuries and medical treatment. |
Key Cases Cited
- People v. Beauchamp, 241 Ill. 2d 1 (2011) (standard for sufficiency; reasonable doubt in appellate review)
- People v. Collins, 106 Ill. 2d 237 (1985) (Be the reasonable-doubt sufficiency framework)
- People v. Ross, 229 Ill. 2d 255 (2008) (appellate review limits re-trying sufficiency questions)
- People v. Cochran, 178 Ill. App. 3d 728 (1989) (great bodily harm question for the trier of fact)
- People v. Figures, 216 Ill. App. 3d 398 (1991) (distinguishes ordinary from great bodily harm via Mays framework)
- People v. Mays, 91 Ill. 2d 251 (1982) (defining bodily harm in battery context; baseline for harm)
- In re J.A., 336 Ill. App. 3d 814 (2003) (illustrates assessment of great bodily harm where wounds described)
- In re T.G., 285 Ill. App. 3d 838 (1996) (requires more than incidental injury to prove great bodily harm)
- People v. Doran, 256 Ill. App. 3d 131 (1993) (photographic evidence supporting great bodily harm)
- People v. Smith, 6 Ill. App. 3d 259 (1972) (great bodily harm can be shown by significant injuries and treatment)
- People v. Jordan, 102 Ill. App. 3d 1136 (1981) (great bodily harm not dependent on hospitalization or medical care)
- People v. Matthews, 126 Ill. App. 3d 710 (1984) (great bodily harm shown by serious injury despite limited medical care)