People v. Little, 129 N.E.3d 113

Defendant Jermon Little was charged with aggravated battery of a peace officer and criminal damage to government-supported property after a nighttime confrontation in a bar parking lot with three Burnham police officers.
State witnesses (Chief Belos, Officers Bolin and Russell) testified that Little struck Chief Belos, resisted arrest, shoved Officer Bolin into a storefront window, kicked Bolin, and damaged a squad-car window during transport.
Defense witnesses (defendant, his sister, and niece) testified police used excessive force: Officer Russell struck and repeatedly tased Little; defendant did not assault officers or break the car window. Photographs of alleged injuries were introduced.
After the close of evidence the trial was continued for the judge’s review; nearly three months later the court mistakenly announced findings of guilty before hearing defense closing argument.
Upon being corrected, the trial court reopened the case, allowed defense counsel to argue (State waived rebuttal), then reaffirmed its findings, crediting officer testimony and sentencing Little to two years’ probation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for aggravated battery and criminal damage	State: Officer testimony sufficed to prove Little hit Chief Belos, shoved/struck Officer Bolin, kicked Bolin, and broke a squad-car window	Little: Officer testimony was implausible/conflicting; photos and defense witnesses showed officers used force and defendant did not commit the charged acts	Convictions affirmed—viewing evidence in State’s favor, a rational trier of fact could credit the officers and convict
Right to closing argument after premature bench verdict	State: Reopening and permitting belated argument preserves the Sixth Amendment right if judge remains open-minded	Little: Premature announcement rendered any belated argument futile; judge was biased and confirmation bias prevented fair consideration	Reopening suffices when the record shows the judge was willing to hear argument with an open mind; here the judge reopened, promised to keep an open mind, heard argument, and the conviction stands

Herring v. New York, 422 U.S. 853 (1975) (Sixth Amendment guarantees right to closing argument; denial requires reversal)
Jackson v. Virginia, 443 U.S. 307 (1979) (standard for reviewing sufficiency of evidence)
People v. Wright, 2017 IL 119561 (Ill. 2017) (deference to trial court credibility findings in sufficiency review)
People v. Beauchamp, 241 Ill. 2d 1 (Ill. 2011) (deference to trier of fact on evidentiary inferences)
People v. Cunningham, 212 Ill. 2d 274 (Ill. 2004) (record may compel reversal if no reasonable person could accept trial court’s view)
People v. Daniels, 51 Ill. App. 3d 545 (Ill. App. 1977) (reopening for belated summation can cure inadvertent denial when judge appears open-minded)
United States v. Price, 795 F.2d 61 (10th Cir. 1986) (reopening ok where record shows judge kept open mind)
United States v. King, 650 F.2d 534 (4th Cir. 1981) (reversal where judge said argument would be futile)
United States v. Walls, 443 F.2d 1220 (6th Cir. 1971) (reversal where judge expressed he had made up his mind)
Spence v. State, 463 A.2d 808 (Md. 1983) (court held premature verdict requires reversal; judge cannot fairly unring the bell)