People v. Fields
2013 IL App (2d) 120945
Ill. App. Ct.2013Background
- In April 2007, a gang-related altercation led to shots being fired in an Aurora apartment building stairwell; Rashod Waldrop died and Jonathan Phillips sustained a head wound. Darvin Henderson was the shooter; Tuan C. Fields (defendant) was charged as accountable for Henderson’s acts.
- Video and witness evidence showed Fields admit Henderson into the secured lobby, obtain a gun (from Townes), give Henderson access, and lead Phillips and Waldrop toward the stairwell; shots were then fired.
- Police found bullet holes, fragments, and jackets in/near the stairwell; Phillips was found unconscious and bleeding with what an officer described as an apparent gunshot wound to the head.
- Fields was convicted by a jury of first-degree murder and attempted first-degree murder and sentenced to consecutive prison terms. He appealed the attempted-murder conviction and raised ineffective-assistance claims about counsel’s failure to object to gang-affiliation evidence.
- The trial court held a Krankel hearing on Fields’ pro se ineffective-assistance motion where the State actively participated; the court denied appointment of counsel and denied relief. Fields appealed that denial as well.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence for attempted murder (Phillips) | Evidence (shots fired, jackets/fragments, officer observations, defendant’s statements) supports that Phillips was shot and defendant intended to kill via Henderson | No medical proof Phillips was shot; injury could be from blunt trauma or chaos—insufficient to prove attempted murder beyond reasonable doubt | Affirmed: viewing evidence in prosecution’s favor, a rational jury could infer Phillips was shot and that defendant, as accountable, intended and took a substantial step toward killing |
| Ineffective assistance for failing to object to gang-affiliation evidence | Gang evidence provided context for motive/conflict; even if objected to, other strong proof of guilt would remain | Counsel’s failure to object to irrelevant/prejudicial gang evidence deprived defendant of a fair trial | Rejected: even assuming deficiency, no prejudice shown given overwhelming non-gang evidence of Fields’ role |
| Proper procedure at Krankel hearing (pro se posttrial ineffective-assistance motion) | The court may question defendant and counsel; State’s brief factual responses are permissible | The State’s active, adversarial participation converted the preliminary inquiry into an adversarial hearing while defendant was unrepresented | Reversed in part: remand for a new Krankel inquiry before a different judge without adversarial State participation |
| Harmlessness of State’s participation at the Krankel hearing | Participation did not affect the correctness of substantive rulings; errors were harmless | Adversarial State role forced pro se defendant to argue against both counsel and prosecutor | Court held the procedure was improper and not harmless; remand required |
Key Cases Cited
- People v. Krankel, 102 Ill. 2d 181 (establishes procedure for court’s preliminary inquiry into pro se claims of ineffective assistance)
- Strickland v. Washington, 466 U.S. 668 (framework for ineffective-assistance claims: deficiency and prejudice)
- People v. Cooper, 194 Ill. 2d 419 (standard for sufficiency-of-the-evidence review)
- People v. Moore, 207 Ill. 2d 68 (discusses when appointment of counsel is required for pro se posttrial claims)
- People v. Cabrales, 325 Ill. App. 3d 1 (remand required where preliminary inquiry became adversarial and defendant was unrepresented)
- People v. Albanese, 104 Ill. 2d 504 (applies Strickland in Illinois context)
- People v. Evans, 209 Ill. 2d 194 (explains reasonable-probability prejudice standard)
- People v. Larson, 379 Ill. App. 3d 642 (circumstantial evidence need not exclude all reasonable alternative explanations)