People v. Maya
2017 IL App (3d) 150079
| Ill. App. Ct. | 2018Background
- Defendant Erick Maya was convicted of first-degree murder, attempted first-degree murder, and unlawful use of a weapon by a felon for the February 13, 2014 shooting that killed Briana Valle and injured Alicia Guerrero.
- The State introduced extensive Facebook and text-message communications (between Maya and victims/witnesses) and evidence connecting Maya to a firearm and to the neighborhood (taxi rides, ankle-monitor logs, eyewitness sightings, clothing with GSR particles).
- Key communications included (1) messages between Maya and J.S. (asking her to wait for him), (2) messages between Maya and Brian Lopez about buying a gun, and (3) lengthy threatening and sexually explicit texts from Maya to Briana (captured on S.M.’s phone) demonstrating jealousy, threats, and planning.
- The trial court admitted those communications (Facebook transcripts authenticated by Facebook’s custodian certificate under the business-records exception) and the jury received no limiting instruction (IPI Crim. 4th No. 3.14) on other-acts evidence; defense did not request the instruction.
- Maya filed multiple pro se posttrial motions alleging ineffective assistance of counsel; the trial court declined to inquire into many of those claims. On appeal Maya challenged admission/cumulative effect of bad-acts evidence, the hearsay/business-records ruling, counsel’s failure to request a limiting instruction (ineffective assistance), and the adequacy of the court’s Krankel inquiry.
Issues
| Issue | State's Argument | Maya's Argument | Held |
|---|---|---|---|
| Admission/cumulative effect of Facebook/text messages and other bad-acts evidence | Evidence was relevant to motive, intent, preparation, identity, and timeline; probative value not substantially outweighed by prejudice | Combined volume and content of other-acts evidence created "overkill" and undue prejudice under Rules 403/404(b) | Court affirmed: messages were probative (identity, motive, preparation); cumulative presentation did not produce prohibited "mini-trial" or undue prejudice |
| Failure to give limiting instruction (IPI Crim. 4th No. 3.14) sua sponte | No duty to give instruction sua sponte; State says instruction not requested | Court should have given limiting instruction or counsel was ineffective for failing to request it | Court: no sua sponte duty; counsel’s failure not prejudicial — no reasonable probability outcome would differ; ineffective-assistance claim denied |
| Facebook transcripts admitted under business‑records exception (hearsay) | Facebook custodian’s certificate satisfied Rule 803(6)/902(11) foundation for automated records | Records are not business records and are hearsay | Court affirmed admission: certificate complied with Rule 902(11) and supported business-records exception |
| Posttrial pro se ineffective-assistance (Krankel) inquiry | Trial court should conduct preliminary inquiry when defendant raises pro se ineffectiveness claims | Maya argued trial court failed to inquire into 33 pro se claims and denied opportunity to argue them | Court accepted State’s concession of error and remanded for a proper Krankel preliminary inquiry into pro se claims |
Key Cases Cited
- Old Chief v. United States, 519 U.S. 172 (importance of guarding against evidence that lures jurors to decide on improper grounds)
- Strickland v. Washington, 466 U.S. 668 (standards for ineffective assistance of counsel)
- People v. Donoho, 204 Ill. 2d 159 (other-crimes evidence generally inadmissible to show propensity)
- People v. Nunley, 271 Ill. App. 3d 427 (overreliance on detailed other-act evidence can create a prejudicial mini-trial)
- People v. Bedoya, 325 Ill. App. 3d 926 (reversal where repetitive other-crimes testimony constituted "overkill")
- People v. Caffey, 205 Ill. 2d 52 (abuse-of-discretion standard for evidentiary rulings)