People v. Jones
70 N.E.3d 1264
| Ill. App. Ct. | 2017Background
- Defendant Michael Jones was charged with attempted first-degree murder, aggravated domestic battery, unlawful use/possession of a weapon by a felon, and aggravated battery for stabbing his ex-girlfriend, Cherelle Richardson, on May 26, 2013; Richardson survived emergency surgery for a near‑heart chest wound.
- The trial court reviewed Richardson’s prior (2009) mental‑health records in camera and denied defense access, finding them not relevant to the incident; defense preserved a motion to reconsider and was told it could renew at trial if impeachment became relevant.
- Richardson testified she was stabbed by Jones during an argument; video showed her leaving the house bleeding and showed Jones later limping and reaching across his body to close a car door; no weapon was recovered and blood on the sidewalk matched Richardson.
- Defense presented physical‑therapy expert Dr. Tracy Camaj, who tested Jones and opined his severe joint deformities and weak grip made it unlikely (but not impossible) he could stab Richardson; she acknowledged Jones gave less than full effort on testing and that dynamometers are larger than knives.
- The trial court acquitted Jones of weapon possession and attempted murder but convicted him of aggravated domestic battery; the court found Dr. Camaj credible but concluded her tests did not preclude the possibility Jones stabbed Richardson and credited the victim’s account.
- Jones appealed, arguing insufficient evidence, judicial bias/predetermination by the trial judge, and a denial of his right to present a full defense when mental‑health records were excluded; the appellate court affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of the evidence to prove aggravated domestic battery | The State: evidence (victim testimony, medical injury, video, defendant’s statement) supports conviction | Jones: expert proved severe deformities made him incapable of stabbing Richardson | Affirmed — evidence, viewed favorably to prosecution, supports conviction; expert testimony did not make guilt unreasonable or impossible |
| Trial‑court bias / predetermination | The State: court fairly assessed credibility and evidence | Jones: judge prejudged defense, rejected theory before defense expert testified | Affirmed — no bias; court questioned relevance of records and later considered defense evidence; remarks were within trial judge’s fact‑finding role |
| Exclusion of victim’s mental‑health records / right to present defense | The State: records not relevant to the charged incident; court allowed renewal if impeachment became necessary | Jones: exclusion prevented probing victim’s history of mental illness and supporting theory she self‑inflicted wound | Affirmed — records were reviewed in camera and not preserved in the appellate record; Jones failed to have those in camera materials sealed and preserved, so appellate challenge fails |
Key Cases Cited
- People v. Evans, 209 Ill. 2d 194 (standard for sufficiency of the evidence review)
- People v. Herrett, 137 Ill. 2d 195 (trier of fact not required to accept every explanation consistent with innocence)
- Doser v. Savage Mfg. & Sales, Inc., 142 Ill. 2d 176 (weight of expert testimony depends on supporting facts and reasons)
- People v. Tara, 367 Ill. App. 3d 479 (trial court may accept or reject expert testimony even if uncontradicted)
- People v. Wallenberg, 24 Ill. 2d 350 (trial court may not decide cases based on private knowledge outside the record)
- People v. Deleon, 227 Ill. 2d 322 (appellant must preserve sealed in‑camera materials for appellate review)