People v. Patterson
2012 IL App (1st) 101573
Ill. App. Ct.2012Background
- Ronald Patterson, a 15-year-old, was charged with three counts of aggravated criminal sexual assault after being transferred to criminal court under 705 ILCS 405/5-130(1)(a).
- A police interrogation occurred at night without contacting Patterson’s parent or a responsible adult despite statutory duties; Patterson signed a typewritten statement after initial questioning.
- The trial court admitted the signed statement over suppression challenges, and Patterson was convicted on all counts.
- Evidence was sought to be shown that the alleged victim’s cervix redness could be explained by intercourse with her boyfriend, as an alternative to Patterson’s involvement.
- On appeal, the court held the automatic transfer provision constitutional, reversed the admission of the signed statement, and remanded for a new trial with directed handling of the rape-shield/alternative-explanation issue.
- The court vacated Patterson’s 36-year sentence and remanded for a new trial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Constitutionality of automatic transfer provision | Patterson argues the transfer statute is unconstitutional | State defends statute as constitutional | Constitutionality upheld |
| Admissibility of Patterson’s police-station statement | Statement was involuntary due to lack of adult assistance | Statement was voluntary and properly obtained | Statement improperly admitted; remand for new trial |
| Rape-shield evidence—alternative explanation | Evidence of E.C.’s intercourse with her boyfriend should be admissible to explain physical findings | Rape shield barred such evidence | Trial court abused discretion; on retrial allow evidence of boyfriend’s intercourse to explain redness |
| Effect of error on sentencing | Errors affected conviction and sentencing integrity | No reversible error tied to sentence | Sentence vacated; remand for new trial |
| Effectiveness of counsel regarding suppression hearing | Ineffective assistance in not presenting intellectual-deficit evidence | Waiver of consideration of intellect as factor acceptable | Issue not resolved on appeal; remand issue remains for retrial |
Key Cases Cited
- People v. P.H., 145 Ill.2d 209 (1991) (automatic transfer validity under due process principles)
- People v. J.S., 103 Ill.2d 395 (1984) (juvenile transfer constitutionality under prior standards)
- People v. McDaniel, 326 Ill. App.3d 771 (2001) (voluntariness considerations for juvenile confessions)
- In re G.O., 191 Ill.2d 37 (2000) (special care for juveniles in custodial interrogations)
- People v. Griffin, 327 Ill. App.3d 538 (2002) (role of youth officer and duties toward juvenile rights)
- People v. Santos, 211 Ill.2d 395 (2004) (rape shield and impeachment vs. defense)
- People v. Freeman, 404 Ill. App.3d 978 (2010) (rape shield; balancing probative value of alternate explanations)