People v. Jones
2017 IL App (1st) 143403
| Ill. App. Ct. | 2017Background
- Defendant Michael Jones was tried by the bench for stabbing his ex-girlfriend, Cherelle Richardson; charged with attempted first-degree murder, aggravated domestic battery, unlawful use/possession of a weapon by a felon, and aggravated battery. The court acquitted on weapon-possession and attempted murder counts and convicted on aggravated domestic battery.
- Richardson testified she was stabbed in the chest at Jones’s home, required emergency surgery for a wound that penetrated toward the heart, and identified Jones as the assailant; no weapon was recovered.
- Defense theory: Richardson stabbed herself; defense physical‑therapy expert (Dr. Camaj) testified Jones’s severe deformities, limited range of motion, and weak grip made it unlikely or extremely difficult for him to stab Richardson.
- Trial court found Dr. Camaj credible but concluded her exam did not preclude Jones from stabbing Richardson (her opinion admitted it was not impossible), credited other evidence (small entry wound, video of Jones using his arm to close a car door, Richardson’s testimony), and found the self‑infliction theory implausible.
- Before trial the court reviewed Richardson’s prior mental‑health records in camera and excluded them as not relevant to the charged incident; defense argued the records would support the self‑stab theory and impeachment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence to convict of aggravated domestic battery | State: Evidence (victim testimony, medical injury, video, Jones’s conduct) supports that Jones stabbed Richardson | Jones: Expert showed physical deformities/weakness made stabbing impossible or highly unlikely | Affirmed — viewing evidence in light most favorable to prosecution, a rational trier of fact could convict; expert did not rule out possibility and court credited other evidence |
| Judicial bias / trial court prejudged defense | State: Court lawfully evaluated credibility and evidence; remarks reflected experience, not reliance on extrinsic facts | Jones: Court’s pre‑trial comments and later remarks show it rejected his theory before defense evidence was presented | Affirmed — no plain error; court considered defense evidence, credited expert but found it not dispositive; remarks were permissible credibility evaluations |
| Exclusion of victim’s mental‑health records (confrontation/impeachment) | State: Records were not relevant to the charged incident and court properly reviewed them in camera | Jones: Exclusion denied right to full defense and to probe victim’s mental history for self‑infliction theory | Affirmed — issue not preserved for appeal and records are not in the appellate record; absent sealed in‑camera record, presumption stands that court acted lawfully |
Key Cases Cited
- People v. Evans, 209 Ill. 2d 194 (discusses standard for reviewing sufficiency of the evidence)
- People v. Hall, 194 Ill. 2d 305 (appellate role in weighing sufficiency; not to retry facts)
- People v. Herrett, 137 Ill. 2d 195 (trier of fact not required to accept every possible innocence explanation)
- Doser v. Savage Manufacturing & 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 base findings on undisclosed personal knowledge contradicting the record)
- People v. Hobley, 182 Ill. 2d 404 (trial courts may use life experience when evaluating credibility)
- People v. Deleon, 227 Ill. 2d 322 (appellant must preserve/seal in‑camera material for appellate review; absence of record resolves presumption in favor of trial court)