People v. Lloyd
2013 IL 113510
| Ill. | 2013Background
- Lloyd was convicted on seven counts of criminal sexual assault under 12-13(a)(2) for vaginal penetration of PV, age 13.
- Indictments allege acts between Sept. 1, 2008 and Jan. 7, 2009; prosecution sought to prove Lloyd knew PV was unable to understand the nature of the acts or to give knowing consent.
- PV, 13, was a family friend’s relative living with her mother and relatives; incidents occurred in a van and involved touching, oral sex, and coercive statements.
- Appellate court affirmed six counts and reversed one for a jury instruction issue; held that knowledge of PV’s age could satisfy the statute’s mental-impairment requirement.
- Illinois Supreme Court held that proof of the victim’s age alone is insufficient; the State must show Lloyd knew facts beyond age that prevented PV from understanding the acts or consenting, and all seven counts are reversed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does 12-13(a)(2) require knowledge of factors beyond age? | People argued age suffices to show lack of consent/understanding. | Lloyd contends age alone proves lack of understanding/consent. | Age alone insufficient; require knowledge of additional facts. |
| What is the proper interpretation of 'unable to understand the nature of the act' and 'unable to give knowing consent'? | State's broad reading based on age could stand. | Knowledge must concern more than age; case-by-case fact-specific. | Necessary to show defendant knew facts beyond age that disabled understanding or consent. |
| Does the statutory framework using age-based offenses undermine 12-13(a)(2) if age alone supports conviction? | Age knowledge could satisfy 12-13(a)(2). | Age-based provisions demonstrate the legislature’s use of age as an element; 12-13(a)(2) should not be read to override others. | State’s age-alone reading would create absurd results and undermine other provisions. |
| Should the convictions be sustained on any grounds given the evidence? | Total evidence could prove lack of understanding/consent. | Evidence relied on age and immaturity is insufficient without other factors. | Convictions reversed; evidence insufficient to prove 12-13(a)(2) beyond age alone. |
Key Cases Cited
- People v. Hollins, 2012 IL 112754 (IL Supreme Court, 2012) (age-based offenses; discussion of consent and age protections)
- Blake v. People, 287 Ill. App. 3d 487 (Ill. App. Ct. 1997) (young age as a factor in inability to understand the act)
- Weiss v. People, 263 Ill. App. 3d 725 (Ill. App. Ct. 1994) (evidence of severe cognitive impairment showing lack of consent)
- Maloney v. People, 201 Ill. App. 3d 599 (Ill. App. Ct. 1990) (victim's mental capacity as basis for lack of understanding)
- Sullivan v. Louisiana, 508 U.S. 275 (U.S. Supreme Court, 1993) (jury-trial rights; standard for evaluating conviction integrity)