People v. Doolan
67 N.E.3d 485
| Ill. App. Ct. | 2016Background
- Around midnight on June 22–23, 2010, defendant Matthew Doolan and codefendants (Ambrose gang members) stopped at a Bridgeview Shell station; a confrontation occurred with occupants of a black Maxima (Abdallah, Rahman, Dajani).
- Surveillance video and eyewitnesses show Miller approaching the Maxima, opening the passenger door and kicking the seated Abdallah; defendant (Doolan) squared up and delivered at least one punch to Abdallah’s head and later struck Rahman during the melee.
- Abdallah collapsed after jumping/leaping over the van and later died; autopsy and medical experts concluded death was a homicide caused by stress/adrenergic surge in the context of blunt-force facial trauma and an enlarged heart.
- Defendant was charged (and convicted by jury) of first degree murder (intentional/knowing and felony murder theories), vehicular invasion (predicated on Miller’s entry/kick), and aggravated battery; sentenced to an aggregate 24 years.
- On appeal defendant argued insufficiency of evidence as to accountability (no common design/shared intent) for murder and vehicular invasion and alternatively that murder should be reduced to involuntary manslaughter.
Issues
| Issue | Plaintiff's Argument (People) | Defendant's Argument (Doolan) | Held |
|---|---|---|---|
| 1. Was defendant accountable for Miller’s vehicular invasion (entry/kick into car)? | Defendant aided, encouraged, and participated in a gang-motivated assault; stood by, shouted gang slogans, and participated in violence — thus accountable for Miller’s vehicular invasion. | He did not share a common criminal design, was not involved in planning, and did not enter the vehicle; minimal or no contact with Abdallah. | Yes. Evidence (video, witnesses) supports accountability for Miller’s vehicular invasion. |
| 2. Was defendant accountable for Abdallah’s death (first degree murder under intentional/knowing or felony murder)? | Defendant punched Abdallah and was part of the violent group whose acts set in motion the events causing death; medical testimony tied the altercation to death; jury could infer requisite intent or knowledge. | Any contact was at most a glancing blow; Abdallah died from a cardiac event precipitated by running/jumping and preexisting conditions — defendant lacked intent/knowledge; at most reckless conduct (involuntary manslaughter). | Yes. Viewing evidence in light most favorable to the State, the jury could infer intent/knowledge and find defendant guilty of first degree murder; convictions affirmed. |
| 3. Whether murder conviction should be reduced to involuntary manslaughter | State: evidence supports intentional/knowing murder; alternatively felony murder valid because defendant accountable for vehicular invasion. | Defendant: lacked mental state for murder; death not foreseeable from punches; only reckless risk. | No reduction. The jury could reasonably infer the necessary mental state for first degree murder; conviction stands. |
| 4. Mittimus error (aggravated battery specification) | State requested correction to reflect the charged offense (aggravated battery on or about a public way). | No contest in briefs. | Court ordered mittimus corrected to show aggravated battery "on or about a public way." |
Key Cases Cited
- People v. Brown, 2013 IL 114196 (standard for sufficiency review)
- People v. Fernandez, 2014 IL 115527 (accountability/common-design rule)
- In re W.C., 167 Ill. 2d 307 (acts in furtherance of a common design attributable to all)
- People v. Perez, 189 Ill. 2d 254 (inference of common purpose from surrounding circumstances)
- People v. Batchelor, 171 Ill. 2d 367 (factors for accountability: presence, flight, failure to report)
- People v. Brackett, 117 Ill. 2d 170 (causation where defendant’s acts set in motion chain of events leading to death)
- People v. Davis, 233 Ill. 2d 244 (general verdict on multiple murder theories presumes jury found the most serious offense)
- People v. DiVincenzo, 183 Ill. 2d 239 (punching/kicking can support first degree murder if requisite mental state present)
- People v. Gresham, 78 Ill. App. 3d 1003 (noting that death is not usually the probable result of a bare-fist blow, but mental state controls)
- People v. Isunza, 396 Ill. App. 3d 127 (vehicular invasion established by reaching into/opening vehicle and striking occupant)
- People v. Hall, 194 Ill. 2d 305 (totality of evidence standard for conviction)
- People v. Jackson, 232 Ill. 2d 246 (circumstantial evidence may sustain conviction)