People v. Hadden
2015 IL App (4th) 140226
Ill. App. Ct.2016Background
- In June 2012 Hadden was charged with solicitation of murder for hire for allegedly procuring an undercover agent (posing as a hitman) to kill Michael Anderson in exchange for money.
- Hadden was detained in McLean County jail on a separate burglary charge; two surreptitious audio recordings were made of Hadden (one via inmate barber Lyons, one via Illinois State Police undercover agent Luster) discussing paying to have Anderson killed.
- Recordings show Hadden expressing he wanted Anderson “gone completely,” negotiating a $1,000 price (with $500 up front), giving Anderson’s name/address, a description of the residence, and his girlfriend’s phone number to coordinate payment after bonding out.
- Hadden testified he was merely venting, lacked funds, did not intend to pay, and did not believe he would bond out; the jury convicted him and the trial court sentenced him to 25 years for solicitation (plus 5 years for burglary, consecutive).
- Posttrial, Hadden complained in allocution that counsel failed to obtain Lyons’ sentencing transcripts and failed to file an unspecified motion; the trial court did not inquire further. Hadden filed a postconviction petition asserting ineffective assistance claims; the trial court summarily dismissed it as frivolous and patently without merit.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence: whether an "agreement" existed for solicitation of murder for hire | Recordings and circumstantial facts show Hadden solicited Luster to kill Anderson for money; jury reasonably inferred intent and agreement | No enforceable "agreement" existed because a condition precedent (Hadden bonding out) never occurred; at most attempted solicitation | Affirmed conviction: jury could reasonably find an agreement existed; plain meaning of "agreement" applies (not technical contract law), evidence sufficient under Jackson/Wheeler standard |
| Trial court's duty to inquire into posttrial ineffective-assistance claims (Krankel inquiry) | Allegations were conclusory and lacked specific factual support to trigger Krankel; no inquiry required | Claimed counsel failed to obtain Lyons’ sentencing transcripts and failed to file a motion; trial court should have inquired | No Krankel hearing required: claims were bald/conclusory without factual detail showing how counsel's acts prejudiced Hadden |
Key Cases Cited
- People v. Wheeler, 226 Ill. 2d 92 (discusses sufficiency-of-the-evidence standard applied on review)
- Jackson v. Virginia, 443 U.S. 307 (establishes standard for reviewing sufficiency of the evidence)
- People v. Boyce, 2015 IL 117108 (discusses attempted solicitation doctrine)
- People v. Krankel, 102 Ill. 2d 181 (requires trial-court inquiry when defendant raises colorable ineffective-assistance claim)
- People v. Reed, 361 Ill. App. 3d 995 (conclusory posttrial claims do not compel Krankel inquiry)
- People v. Peacock, 359 Ill. App. 3d 326 (distinguished; defendant supported claims with factual specifics triggering Krankel)