People v. Rodriguez, 79 N.E.3d 345

Background

In October 2008, 15‑year‑old Sebastian Rodriguez was charged with first‑degree murder for the shooting death of 13‑year‑old Sameere Conn; at the time 15‑year‑olds charged with murder were automatically tried as adults.
Police obtained a search warrant nine days after the shooting for Rodriguez’s home (identified by prior arrest records) seeking a hooded sweatshirt, a list of names, and a handgun; officers found a .357 revolver under a bathroom floorboard and several hoodies.
At trial, eyewitnesses identified Rodriguez as the shooter (some testimony varied), gunshot residue testing was largely negative, and an Illinois State Police firearms examiner testified the recovered revolver fired the bullet from the scene.
Rodriguez moved to suppress the evidence from the search (arguing lack of nexus/probable cause) and sought a Frye hearing to challenge the general acceptance of toolmark/firearm‑identification methodology; both motions were denied.
A jury convicted Rodriguez of first‑degree murder; the circuit court sentenced him to 25 years for murder plus a mandatory 25‑year firearm enhancement (total 50 years).
After appeal was filed, the Illinois legislature raised the automatic transfer age from 15 to 16 for first‑degree murder and changed sentencing rules for offenders under 18; Rodriguez argued those amendments apply retroactively.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Probable cause for warrant to search home	Warrant affidavit established nexus: eyewitness IDs, purported "kill list," and prior address support fair probability evidence (gun, hoodie, list) would be at home	Probable cause to arrest ≠ probable cause to search; affidavit lacked close nexus between crime and items 10 days later at home	Warrant was supported by probable cause; inference that a teenager would keep weapon/clothing at home was reasonable; suppression denied was proper
Admissibility of firearms/toolmark ID (Frye)	NRC report undermines general acceptance; Frye hearing required because methodology is subjective and lacks statistical error rates	Firearm/toolmark ID is longstanding and routinely admitted in Illinois; criticisms go to weight, not admissibility	Frye hearing not required; methodology not "novel" in Illinois and concerns addressed on cross‑examination; admission upheld
Retroactivity of 2016 statutory amendment raising automatic transfer age	Amendment raising transfer age to 16 and related juvenile‑friendly sentencing provisions should apply retroactively to pending cases, so sentence must be vacated and case remanded to juvenile court	State argued procedural/practical concerns but Illinois precedent and Statute on Statutes support retroactive application of procedural changes only if practicable	Amendment applies retroactively; court vacated Rodriguez’s sentence and remanded to juvenile court for disposition (State may seek discretionary transfer)

Key Cases Cited

Frye v. United States, 293 F. 1013 (D.C. Cir. 1923) (establishes general‑acceptance test for novel scientific evidence)
Ventresca v. United States, 380 U.S. 102 (U.S. 1965) (issuing magistrate's probable‑cause determination entitled to deference)
Landgraf v. USI Film Products, 511 U.S. 244 (U.S. 1994) (framework for determining retroactivity of statutes)
People v. Fisher, 340 Ill. 216 (Ill. 1930) (firearm identification admissible as expert testimony)
People v. McKown, 226 Ill. 2d 245 (Ill. 2007) (Frye required for novel scientific evidence; HGN example)
People v. McCarty, 223 Ill. 2d 109 (Ill. 2006) (probable cause for searches; practical, commonsense inquiry)
People v. Hammers, 35 Ill. App. 3d 498 (Ill. App. Ct. 1976) (upholding inference that weapon used in crime could be at defendant's home days later)
People v. Weinger, 63 Ill. App. 3d 171 (Ill. App. Ct. 1978) (logical inference that clothing/jewelry used in crime may be kept at defendant's residence)
People ex rel. Alvarez v. Howard, 2016 IL 120729 (Ill. 2016) (amendment raising juvenile transfer age applied retroactively to pending cases)