People v. Sargent, 239 Ill. 2d 166

In December 2004, defendant was charged with one count of predatory criminal sexual assault of his minor stepson J.W. and three counts of predatory criminal sexual assault plus two counts of aggravated criminal sexual abuse of his other stepson M.G.
The State sought and obtained admission of hearsay statements from the victims under 115-10, including videotaped and interview statements; defense motions to suppress an inculpatory statement were denied.
The cases were joined for trial under 114-7, and 115-7.3 allowed evidence of defendant’s conduct with respect to each victim to be admitted in connection with both prosecutions.
At trial, the State introduced the victims’ statements, an expert on child sexual abuse accommodation syndrome, and a videotaped police interview of defendant in which he confessed to various acts.
The jury convicted on all counts; the circuit court sentenced defendant to natural life for predatory sexual assault convictions and seven-year terms for aggravated abuse, to run consecutively to the life sentence.
The appellate court modified the seven-year terms to run concurrently with the life sentence, and the Illinois Supreme Court granted review.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether corpus delicti corroboration was required for M.G. counts	Sargent contends confession alone cannot prove corpus delicti for M.G.	Willingness to admit confession suffices if corroboration exists	Corroboration required; two M.G. counts reversed due to lack of independent corroboration.
Whether the hearsay-instruction under 115-10(c) was required and whether its omission was plain error	Failure to give 115-10(c) instruction violated statute	Instruction not tendered but error non-prejudicial	Plain error not satisfied; no reversal for those counts.
Whether seven-year aggravated sentences must run concurrently with the life sentence	Seven-year terms should run concurrently with life	Sentences should be consecutive	Seven-year terms run concurrently with life; overall structure affirmed for those counts only.
Whether J.W. predatory conviction was supported by the record beyond the confession	Evidence including J.W.’s statements corroborates guilt	Confession alone not corroborated for all counts	upheld; conviction for predatory criminal sexual assault of J.W. affirmed.
Whether the corroboration rule invalidates remaining M.G. predatory counts	Corroboration may relate to overall conduct	Corroboration must relate to each charged act	Remaining M.G. predatory counts reversed; corroboration lacking for multiple offenses.

People v. Lambert, 104 Ill.2d 375 (1984) (corpus delicti requires independent corroboration of confession)
People v. Furby, 138 Ill.2d 434 (1990) (corroboration rule; confession alone insufficient)
People v. Cloutier, 156 Ill.2d 483 (1993) (corroboration required when confession is part of corpus delicti proof)
People v. Willingham, 89 Ill.2d 352 (1982) (confession corroboration required for corpus delicti)
People v. Phillips, 215 Ill.2d 554 (2005) (corroboration may be provided by independent evidence; consider testimony together)
People v. Dalton, 91 Ill.2d 22 (1982) (established corroboration requirement for confessions)
People v. Mitchell, 155 Ill.2d 344 (1993) (instruction and 115-10(b) hearing; plain error analysis)
People v. Hopp, 209 Ill.2d 1 (2004) (plain-error considerations; juror comprehension of instructions)