People v. Jones
2015 IL App (2d) 120717
| Ill. App. Ct. | 2015Background
- Jones was convicted of 12 counts of first-degree murder, attempted first-degree murder, four counts of home invasion, and residential burglary.
- He sought a six-person jury; the trial court denied, citing 12-person statutory requirement.
- Batson challenge alleged the State discriminated against an African-American venireperson, Barnett, in voir dire.
- Jones claimed violation of his right to self-representation due to admonishments about reappointment of counsel if he waived.
- One-act, one-crime analysis led to vacation of most murder and related convictions; counts reduced to two murders and one home invasion.
- Judgment affirmed in part and vacated in part.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a six-person jury was permissible | Jones argues discretionary reduction was prejudicial. | Jones contends denial violated right to jury and Chapman. | Trial court's discretion preserved; prejudice not shown. |
| Batson challenge to African-American venireperson exclusion | State used race-based peremptory challenge against Barnett. | State's reasons were pretextual and race-based. | No clear Batson violation; reasons not clearly erroneous. |
| Right to self-representation and admonishment | Admonishment coerced waiver of counsel. | Admonishment improperly pressured pro se choice. | No improper coercion; admonishment within discretion. |
| One-act, one-crime violations on murder and related convictions | All murders and home invasions should stand under one-act-one-crime. | Multiple convictions improper given single conduct. | Vacate all but two murders and one home invasion; residential burglary vacated. |
Key Cases Cited
- People v. Dockery, 235 Ill. 2d 73 (2009) (jury size discretion and waiver of right to jury)
- Chapman, 194 Ill. 2d 186 (2000) (abuse of discretion in failing to exercise discretion)
- Batson v. Kentucky, 476 U.S. 79 (1986) (three-part test for racial peremptory challenges)
- People v. Easley, 192 Ill. 2d 307 (2000) (Batson framework in Illinois)
- People v. McLaurin, 184 Ill. 2d 58 (1998) (one-act, one-crime doctrine in multiple convictions)
- People v. Cole, 172 Ill. 2d 85 (1996) (one conviction per home invasion when single entry)
- People v. Wiley, 165 Ill. 2d 259 (1995) (juror selection; race-neutralquiry not required to be identical)
- People v. Baez, 241 Ill. 2d 44 (2011) (knowing and intelligent waiver standard for self-representation)
- People v. Lego, 168 Ill. 2d 561 (1995) (need for defendant to understand consequences of waiving counsel)