People v. Dorr, 2022 IL App (1st) 192592-U

Defendant Ricco Dorr was convicted after a bench trial of one count of misdemeanor domestic battery for allegedly slapping his ex‑girlfriend, Emily Garcia, on September 5, 2019; he was sentenced to 210 days in jail after resentencing.
Garcia testified that defendant visited her apartment overnight, they engaged in sexual activity, and defendant slapped her on the left side of her face while they were sitting on the bed; she called police and officers arrived within 10–15 minutes.
Garcia also testified about two prior 2019 domestic‑violence incidents (January and June); the State introduced certified convictions for those incidents as propensity evidence at trial.
Officer Jamie Diaz testified that Garcia was upset, that he did not observe visible injuries, and that officers offered medical/technical services which Garcia declined; Diaz corroborated aspects of Garcia’s account about timing and nature of the incident.
Defendant moved for a directed finding, arguing Garcia’s testimony was internally inconsistent and undermined by her history of psychotic episodes and lack of medication; the trial court denied the motion, found Garcia credible, and convicted.
On appeal defendant challenged sufficiency of the evidence on credibility grounds; the appellate court reviewed the record in the light most favorable to the State and affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the evidence was sufficient to sustain a domestic‑battery conviction given alleged contradictions and Garcia's mental‑health history	Garcia's testimony, corroborated by Officer Diaz and supported by prior convictions admitted at trial, was sufficient for conviction	Garcia's testimony was inconsistent (timing/positions), and her psychotic episodes and lack of medication made her testimony incredible	Affirmed — the court deferred to the trial court's credibility findings and held the evidence was sufficient

People v. Davison, 233 Ill. 2d 30 (establishes Jackson review standard for sufficiency of the evidence)
Jackson v. Virginia, 443 U.S. 307 (federal standard: whether any rational trier of fact could find guilt beyond a reasonable doubt)
People v. Siguenza‑Brito, 235 Ill. 2d 213 (deference to fact‑finder on witness credibility and inconsistency resolution)
People v. Evans, 209 Ill. 2d 194 (reversal only when evidence is so improbable or unsatisfactory that it raises reasonable doubt)
People v. Cunningham, 212 Ill. 2d 274 (fact‑finder determines how flaws in part of testimony affect credibility)
People v. Gray, 2017 IL 120958 (a single credible witness’s testimony can support a conviction)