People v. Max, 980 N.E.2d 243

Defendant Billie Max was manager at MKM Oil’s Mazon store; ATM cash missing from Aug 2007–Apr 2008 totaling about $64,460.
Only Max and area supervisor Seabright had access to the ATM; Seabright audited but did not inspect contents.
ATM journal and processor journal were used to balance; discrepancies existed between dispensed cash and replenishment.
State’s expert testified the ATM appeared to function properly despite shortages; defense challenged admissibility and weight of such testimony.
Defendant testified she did not steal money and described training and procedures for refilling the ATM; she resigned in April 2008.
Prosecution closed with rebuttal arguing defendant’s guilt beyond a reasonable doubt; defense challenged evidence and potential misapplication of “reasonable doubt”.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did prosecutor define reasonable doubt in closing?	Max	Max	No due-process violation; no reasonable-likelihood of lesser standard.
Was appointment of a special prosecutor required?	State	Max	Not abused; no appearance of impropriety warranted appointment.
Was trial counsel ineffective?	State	Max	No ineffective assistance; strategy and decision not deficient.
Was evidence sufficient to prove theft over $10,000?	State	Max	Yes; sufficient expert testimony and circumstantial evidence support guilt.
Do cumulative errors require reversal?	State	Max	No; no reversible errors found individually.

Victor v. Nebraska, 511 U.S. 1 (U.S. 1994) (defining reasonable doubt may vary in form but must convey burden of proof)
People v. Green, 225 Ill. 2d 612 (Ill. 2007) (due process and reasonable doubt standard guidance in Illinois)
People v. Collins, 106 Ill. 2d 237 (Ill. 1985) (sufficiency review; Collins standard for appellate review)
People v. Jackson, 232 Ill. 2d 246 (Ill. 2009) (jury credibility and Collins standard applicability)