People v. Escort, 91 N.E.3d 483

In 1989 Mary Smith was found dead in an abandoned warehouse courtyard; autopsy showed strangulation and blunt‑force head injuries. No initial arrest was made.
Biological swabs (vaginal, rectal, oral) and clothing were submitted in 2011 for DNA testing; sperm was detected on vaginal and rectal swabs and on clothing recovered from the roof.
Cellmark Forensics developed two unknown male DNA profiles from vaginal samples ("unknown male #1" predominant in sperm fraction) and a different profile from a semen stain on pants ("unknown male #2").
Illinois State Police matched unknown male #1 to Michael Escort; comparison of Escort’s cheek swabs showed his profile in the sperm and non‑sperm fractions from the victim’s vaginal swabs but not in the semen stain on the victim’s pants or the sperm fraction of the pantyhose.
Escort was indicted for murder (including felony murder predicated on criminal sexual assault); state introduced one prior aggravated criminal sexual assault conviction at trial. The jury convicted and the court sentenced Escort to 60 years.
On appeal the court reviewed sufficiency of the evidence, focusing on whether DNA and other circumstantial evidence proved Escort committed the murder beyond a reasonable doubt.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence to prove Escort committed the murder beyond a reasonable doubt	DNA shows Escort had sexual intercourse with victim shortly before death; many sperm cells on vaginal swab and medical opinion that death occurred only hours before body was found support inference Escort was last with victim and thus the murderer	DNA only proves Escort had sex with victim within a 72‑hour window; no direct link in time between intercourse and death and no evidence tying Escort to the fatal assault	Reversed conviction: evidence was insufficient — DNA could only show intercourse within 72 hours and did not establish temporal link or that Escort was last person with victim, creating reasonable doubt

Jackson v. Virginia, 443 U.S. 307 (establishes the standard for sufficiency review: whether any rational trier of fact could find guilt beyond a reasonable doubt)
People v. Ehlert, 211 Ill. 2d 192 (circumstantial evidence may sustain a conviction if it proves guilt beyond a reasonable doubt)
People v. Collins, 214 Ill. 2d 206 (reviewing court will not reverse unless evidence is so improbable, unsatisfactory, or inconclusive that it creates reasonable doubt)
People v. Smith, 185 Ill. 2d 532 (if evidence is so unsatisfactory or inconclusive as to create reasonable doubt, conviction must be reversed)
People v. Martin, 26 Ill. 2d 547 (guilt cannot rest on speculation)