People v. Ingram, 946 N.E.2d 1058

Ingram was convicted of first-degree murder after participating in the June 2004 stabbing and beating death of Raymond Greene in his apartment.
The trial included a videotaped statement from Ingram and DNA evidence linking blood on items to Greene.
Rule 431(b) issues were raised regarding voir dire and jury instructions after the amended rule took effect May 1, 2007.
The trial court’s voir dire included Zehr principles and admonitions about burden of proof and presumption of innocence.
The defense argued Rule 431(b) was not properly satisfied and that the court interfered with jury selection, and sought a second-degree murder instruction based on provocation.
The appellate court affirmed the conviction and rejected the claimed errors.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Rule 431(b) compliance	State argues trial complied with 431(b) after Thompson guidance	Ingram contends venire was not properly instructed	No error; compliance established by context of voir dire and instructions
Judicial interference with jury selection	State maintains no improper conduct affected impartiality	Ingram claims judge pressured venire members	No abuse of discretion; forfeiture applies, and voir dire shown to be proper under record
Provocation instruction	State contends no basis for second-degree murder instruction	Ingram argues provocation supports instruction	Instruction properly refused; no substantial provocation evidence

People v. Zehr, 103 Ill.2d 472 (1984) (established four principles governing voir dire in Rule 431(b))
People v. Enoch, 122 Ill.2d 176 (1988) (plain error preservation principles)
People v. Williams, 164 Ill.2d 1 (1994) ( voir dire and Rule 431(b) guidance)
People v. Herron, 215 Ill.2d 167 (2005) (plain error framework for forfeited errors)
People v. Thompson, 238 Ill.2d 598 (2010) (Thompson requires strict Rule 431(b) adherence)
People v. Ware, 407 Ill.App.3d 315 (2011) (contemporary application of Rule 431(b) guidance)