People v. Gray, 2017 IL 120958

On Nov. 1–2, 2011, Matthew Gray and Tina Carthron (former dating partners) spent the evening drinking at Gray’s apartment; the next morning Carthron suffered stab wounds to chest and back and was choked. Gray was charged with attempted murder, aggravated battery, and three counts of aggravated domestic battery.
At trial Carthron testified Gray choked her until she passed out and she later discovered she had been stabbed; DNA tied her blood to a knife found in Gray’s apartment. Gray admitted cutting Carthron’s back with a knife but claimed it was in self-defense after she bit him.
The jury convicted Gray of two counts of aggravated domestic battery and one count of aggravated battery; he was sentenced to concurrent prison terms.
On appeal the Appellate Court held the statutory definition of “family or household members” (which includes persons who have had a dating relationship, without a time limit) was unconstitutional as applied because the prior romantic intimacy ended 15 years earlier; it vacated the domestic-battery convictions and ordered a new trial on aggravated battery.
The Illinois Supreme Court granted review, reversed the appellate court, and remanded for consideration of Gray’s remaining claims, holding the statute’s no-time-limit inclusion of former dating relationships is rationally related to preventing domestic violence and therefore constitutional as applied to these facts.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence to support convictions	State: Carthron’s testimony, DNA on knife, corroborating facts support convictions	Gray: Carthron was too intoxicated and inconsistent to be credible; acted in self-defense	Held: Evidence, viewed favorably to State, was sufficient; jury could reject self-defense
Admissibility/effect of other-crimes evidence	State: prior incidents with Moore were admissible to show pattern/context	Gray: prior domestic-battery evidence warranted new trial on aggravated battery count	Held: Appellate court ordered new trial on aggravated battery (that determination not reached by Supreme Court on merits; remanded)
As-applied substantive due process challenge to definition of “family or household members”	State: legislature rationally may include former dating partners without time limit to curb domestic violence	Gray: applying the no-time-limit definition to a relationship that ended 15 years earlier is arbitrary and violates due process	Held: Statute withstands rational-basis review as applied here; inclusion of former dating partners is rationally related to preventing domestic violence
Remedy and remand	State: convictions should stand; alternative reduction not necessary	Gray: convictions for domestic battery invalid; relief required	Held: Supreme Court reversed appellate court’s as-applied invalidation and remanded for consideration of remaining issues (including other evidentiary claims)

Jackson v. Virginia, [citation="443 U.S. 307"] (standard for sufficiency of the evidence)
People v. Pellegrino, [citation="30 Ill. 2d 331"] (witness intoxication and identification reliability)
People v. Cunningham, [citation="212 Ill. 2d 274"] (deference to jury credibility determinations)
People v. Wilson, [citation="214 Ill. 2d 394"] (domestic-violence statutory purpose and that threat may continue after relationship ends)
People v. Belknap, [citation="2014 IL 117094"] (standard for reviewing sufficiency of evidence)