People v. Hudson
2025 IL App (3d) 240012-U
Ill. App. Ct.2025Background
- Terence T. Hudson was charged in Du Page County, Illinois, with driving while license suspended, fleeing or attempting to elude a police officer, and disobeying a stop sign, after a physical altercation at a hotel led to a police response.
- The State sought and was granted limited permission to introduce evidence of the physical altercation to provide context for Hudson’s subsequent conduct, but specifics of the alleged battery were barred.
- During jury selection, three jurors (19, 51, 115) made equivocal statements regarding deference to police testimony, but were not challenged by defense counsel for cause or with peremptory strikes.
- At trial, prosecution witnesses described the hotel incident as a “physical altercation,” after the court permitted that phrasing over defense objection.
- The jury convicted Hudson on all charges. His motion for a new trial, arguing improper admission of the “altercation” evidence and incorrect jury selection, was denied.
- Hudson appealed, claiming ineffective assistance of counsel for failing to challenge allegedly biased jurors, plain error due to a biased jury, and evidentiary error regarding characterization of the hotel incident.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Ineffective Assistance: Juror Challenge | Counsel did not err or, if so, no prejudice shown | Failure to challenge biased jurors was structural error, so prejudice presumed | No prejudice; Strickland requires actual prejudice, not presumed |
| Plain Error: Biased Jury | No plain error, as no biased jurors and no court obligation | Structural error if tried by a biased jury | No evidence of bias or plain error; court not required to remove sua sponte |
| Admission of "Physical Altercation" | Term provided relevant context; not unduly prejudicial | Use of phrase was prejudicial and irrelevant to specific charges | Allowing term was not an abuse of discretion; not overly prejudicial |
Key Cases Cited
- People v. Smith, 195 Ill. 2d 179 (Ill. 2000) (sets standard for ineffective assistance: deficient performance plus prejudice)
- Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (defining the prejudice prong for ineffective assistance claims)
- People v. Metcalfe, 202 Ill. 2d 544 (Ill. 2002) (jury voir dire and counsel’s strategy)
- People v. Buss, 187 Ill. 2d 144 (Ill. 1999) (voir dire examination must be considered in its entirety)
- People v. Boclair, 129 Ill. 2d 458 (Ill. 1989) (evidentiary rulings are within trial court’s discretion)
- People v. Donoho, 204 Ill. 2d 159 (Ill. 2003) (abuse of discretion standard defined)