People v. Pikes
2013 IL 115171
| Ill. | 2013Background
- Keith Pikes and Lamont Donegan were tried simultaneously for the drive-by murder of Lorne Mosley; Pikes was convicted and sentenced to 27 years. The appellate court reversed, ordering a new trial, and the State appealed to the Illinois Supreme Court.
- The State introduced evidence that both men were Four Corner Hustlers and of a prior incident (the “scooter shooting”) where Donegan shot at Gangster Disciples member Quentez Robinson and was struck by a car; Pikes was not involved in that incident.
- Witnesses (Robinson, Lemon, Merkson, Crowder, Coleman) testified about the scooter incident, subsequent statements by Donegan and Pikes about revenge, acquisition/cleaning of a stolen Toyota with a “jiggler” key, and admissions about the Mosley shooting.
- The trial court admitted the scooter-shooting evidence as relevant to motive and context; the jury was instructed under IPI 3.14 regarding other offenses and convicted Pikes.
- The appellate court held the scooter-shooting evidence was impermissible other-crimes evidence because the State did not prove Pikes committed that prior act, and ordered a new trial.
- The Illinois Supreme Court reversed the appellate court, holding the other-crimes doctrine did not apply because Pikes was not accused of committing the scooter shooting; the evidence was admissible under ordinary relevance principles to show motive and context.
Issues
| Issue | People’s Argument | Pikes’s Argument | Held |
|---|---|---|---|
| Admissibility of scooter-shooting evidence | Incident was part of the events leading to Mosley’s murder and relevant to joint motive/intent; intrinsic to the charged offense | The scooter shooting was a separate "other crime" and inadmissible absent proof Pikes committed it; prejudicial and unnecessary | Evidence admissible: not "other-crimes" vis-à-vis Pikes (he wasn’t involved); judge properly admitted it under ordinary relevance to show motive/context |
| Whether other-crimes threshold (proof defendant committed prior act) applies | Threshold inapplicable because the prior act was not charged to Pikes and was relevant background/integral to the narrative | Threshold applies to any uncharged criminal act introduced against defendant | Threshold does not apply where defendant is not alleged to have committed the prior act; other-crimes doctrine inapplicable |
| Prejudice from gang and scooter-shooting evidence | Probative value in explaining motive and sequence outweighed any prejudice | Evidence risked guilt-by-association and jury speculation via IPI 3.14; the jury could be unfairly biased | No unfair prejudice sufficient to outweigh probative value; any jury instruction concerns did not cause reversible error |
| Whether appellate court should have remanded for new trial | State: appellate court erred in applying other-crimes analysis and ordering new trial | Pikes: admission was reversible error requiring new trial | Reversed appellate court; remanded for consideration of other issues Pikes raised on appeal |
Key Cases Cited
- People v. Thingvold, 145 Ill. 2d 441 (1991) (sets standards for when other-crimes evidence may be admitted and stresses propensity concerns)
- People v. Adkins, 239 Ill. 2d 1 (2010) (recognizes admission of evidence forming a "continuing narrative" of the charged offense)
- People v. Wilson, 214 Ill. 2d 127 (2005) (other-crimes evidence inadmissible if offered only to show propensity)
- People v. Robinson, 167 Ill. 2d 53 (1995) (other-crimes evidence admissible for motive, intent, modus operandi, identity)
- People v. Moss, 205 Ill. 2d 139 (2001) (probative value must not be substantially outweighed by prejudicial effect)
- People v. Richardson, 123 Ill. 2d 322 (1988) (explains risk that other-crimes evidence overpersuades juries)