People v. Sanders, 34 N.E.3d 219

Defendant Derry Sanders (white) was tried and convicted by a jury of two counts of criminal sexual assault (720 ILCS 5/11-1.20(a)(2)) and had previously pleaded guilty to unlawful possession of a controlled substance; he received consecutive prison terms.
The alleged victim, B.J., drank heavily at a bar, left with defendant, went to his apartment, vomited, later awoke to find defendant having sex with her and reported the incident to police; defendant told police the encounter was consensual.
The State moved in limine to exclude sexually suggestive text-message content between B.J. and another man (Lacomba) under Illinois’s rape‑shield statute; the trial court allowed testimony about contact, timing, and Lacomba’s observations but barred the explicit sexual content of the messages.
During voir dire, the State used peremptory strikes against two apparent African‑American venire members; defense counsel lodged a Batson objection asserting a pattern of strikes against African‑Americans, which the trial court found insufficient to establish a prima facie case and declined to require race‑neutral reasons.
At trial Lacomba testified he had texted and spoken with B.J. until about 4:30 a.m. and believed she did not appear intoxicated; the jury convicted on both sexual‑assault counts.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court improperly denied defendant’s Batson challenge	State: no prima facie showing; court correctly found no pattern or other circumstances to infer discrimination	Sanders: the strikes against the first two African‑American venire members required the court to find a prima facie case and ask for race‑neutral explanations	Affirmed: court did not abuse discretion; defendant failed to establish prima facie case and was afforded opportunity to present one
Whether the court erred in excluding the sexual content of B.J.’s text messages under the rape‑shield statute and Sixth Amendment confrontation concerns	State: messages are prejudicial, irrelevant to what defendant knew, and properly excluded to protect complainant	Sanders: messages show B.J.’s state of mind and cognitive ability to consent and third‑party perception (Lacomba) was relevant; exclusion violated confrontation or relevancy principles	Affirmed: exclusion upheld — the content was irrelevant to what defendant knew and would have been harassing/prejudicial; Lacomba could testify about communicative ability without explicit sexual content

Batson v. Kentucky, 476 U.S. 79 (established three‑step framework for peremptory‑strike discrimination claims)
Snyder v. Louisiana, 552 U.S. 472 (even a single discriminatory peremptory strike is forbidden; court must consider totality of circumstances)
Johnson v. California, 545 U.S. 162 (prima facie Batson threshold requires facts permitting an inference of discrimination)
People v. Williams, 209 Ill. 2d 227 (discusses Batson three‑step process and relevant factors)
People v. Rivera, 221 Ill. 2d 481 (trial court’s prima facie Batson finding is a factual determination reviewed for manifest weight)
People v. Davis, 231 Ill. 2d 349 (mere number of struck minority jurors, without more, will not establish a prima facie case)
People v. Schuldt, 217 Ill. App. 3d 534 (evidence excluded by rape‑shield statute remains subject to relevancy review)
People v. Cornes, 80 Ill. App. 3d 166 (confrontation and cross‑examination rights do not extend to irrelevant or collateral matters such as complainant’s prior sexual conduct)