People v. Fields
2017 IL App (1st) 110311-B
| Ill. App. Ct. | 2017Background
- Anthony Fields was convicted by a jury of armed robbery and of being an armed habitual criminal (AHC); he received a 21-year sentence for armed robbery (including a 15‑year firearm enhancement) and a concurrent 10‑year AHC sentence.
- Victim Felicia Rowell testified she was robbed inside a convenience store on December 24, 2009; she identified Fields at a police show‑up about a month later and again at the scene of his detention.
- The trial court had granted defense in limine relief barring admission of Fields’s specific prior convictions for impeachment; the parties instead stipulated only that he had two qualifying prior felonies for AHC.
- Fields testified and offered an alibi/time‑of‑event defense supported by family testimony; the jury convicted on both counts.
- On appeal Fields challenged (1) sufficiency of the evidence (identification and proof of a firearm), (2) constitutionality of the 15‑year enhancement, and (3) ineffective assistance for failing to move to sever; he also argued his AHC predicate AUUW conviction was void under Aguilar.
- The appellate court affirmed both convictions, holding counsel’s strategy was reasonable, the eyewitness and circumstantial evidence sufficed to prove a firearm was used, Public Act 95‑688 revived the firearm enhancement, and McFadden/Perkins allow an unvacated prior AUUW conviction to serve as an AHC predicate.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence to convict of armed robbery & AHC | Rowell’s eyewitness ID and testimony that Fields held a black gun suffice; stipulation established prior felonies for AHC | ID unreliable; State failed to prove he possessed a firearm; prior AUUW void under Aguilar so AHC cannot be proven | Convictions affirmed: eyewitness ID and circumstantial proof of a firearm were sufficient; stipulation + unvacated prior convictions supported AHC |
| Constitutionality of 15‑year firearm sentencing enhancement | The enhancement was revived by Pub. Act 95‑688; Blair controls | Enhancement violates proportionality (Hauschild) | Enhancement is constitutional under Blair; statute revived by Public Act 95‑688 (affirmed) |
| Ineffective assistance for not seeking severance of charges | Joint trial strategy was reasonable; counsel had obtained in limine exclusion of prior conviction details | Failure to move to sever prejudiced Fields because prior convictions would be inadmissible in separate trial | No ineffective assistance: decision not to seek severance falls within reasonable strategy; stipulation mitigated prejudice |
| Whether a prior AUUW conviction voided by Aguilar can serve as AHC predicate | State: McFadden/Perkins permit use of an unvacated prior conviction to establish status/predicate for recidivist statutes | Fields: Aguilar voids the AUUW conviction; invalid conviction cannot be used as predicate | Prior conviction may be used unless it had been vacated before the offense; McFadden/Perkins apply and AHC conviction stands |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (ineffective assistance standard)
- Jackson v. Virginia, 443 U.S. 307 (standard for sufficiency review)
- Lewis v. United States, 445 U.S. 55 (use of prior convictions to establish status for firearms statutes)
- People v. Hauschild, 226 Ill. 2d 63 (invalidated 15‑year enhancement under proportionality clause)
- People v. Blair, 2013 IL 114122 (held Pub. Act 95‑688 revived the firearm enhancement)
- People v. Aguilar, 2013 IL 112116 (found a version of the AUUW statute unconstitutional)
- People v. McFadden, 2016 IL 117424 (held unvacated prior convictions may establish felon status for firearm offenses)
- People v. Edwards, 63 Ill. 2d 134 (severance analysis where admission of related prior would prejudice fair trial)
- People v. Gapski, 283 Ill. App. 3d 937 (failure to seek severance can be reasonable trial strategy)