People v. Dabney, 87 N.E.3d 1012

Defendant Hiram Dabney was charged with four counts of aggravated criminal sexual abuse for touching a child victim (K.J.) on breasts, vagina, buttocks, and for placing his penis against her buttocks on August 10, 2013.
The State sought to admit K.J.’s out-of-court videotaped forensic interview (and drawings) under 725 ILCS 5/115-10; the trial court ruled the statements admissible provided K.J. testified at trial.
At trial K.J. (age 11) testified and described being touched on her breasts and buttocks by defendant; she did not testify at trial that defendant touched her vagina with his hands or her buttocks with his penis, but the videotape contained those additional allegations.
Defense counsel cross-examined K.J.; she answered all questions asked, though defense counsel did not elicit testimony in court about the two specific acts appearing only on the videotape.
The jury convicted defendant on all four counts; defendant appealed solely alleging a Confrontation Clause violation from admission of the videotaped statement.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether admitting the child’s videotaped out-of-court statement violated the Confrontation Clause	The State: Confrontation Clause satisfied because K.J. testified at trial, was under oath, and answered all defense questions — defendant had opportunity to cross-examine.	Dabney: K.J. did not testify at trial to two charged acts (vaginal touching and penis on buttocks), so those parts of the videotape were not subjected to cross-examination and admission violated Confrontation Clause.	Court held no violation: K.J. was present, under oath, and answered defense questions; Confrontation Clause does not require the declarant to testify to every detail in the videotape.
Whether defendant preserved the Confrontation Clause objection	The State: Defendant forfeited the claim by not objecting at trial or raising in posttrial motion.	Dabney: Acknowledged forfeiture but urged plain-error review.	Court honored forfeiture because no constitutional error occurred; plain-error not reached.

Crawford v. Washington, 541 U.S. 36 (Confrontation Clause bars admission of testimonial statements unless witness is available for cross-examination)
People v. Walker, 232 Ill.2d 113 (plain-error doctrine framework)
People v. Herron, 215 Ill.2d 167 (plain-error analysis and burden on defendant)
People v. Kitch, 239 Ill.2d 452 (child-victim statements: must meet §115-10 and Confrontation Clause)
People v. Leonard, 391 Ill. App.3d 926 (witness present and answering questions satisfies Confrontation Clause even if memory is limited)
People v. Learn, 396 Ill. App.3d 891 (contrasting outcome; court here disagreed with its reasoning)
People v. Bryant, 391 Ill. App.3d 1072 (victim testified and answered defense questions; videotape admissible)
People v. Major-Flisk, 398 Ill. App.3d 491 (same principle: presence and cross-examination opportunity satisfied Confrontation Clause)