People v. Smith
2025 IL App (3d) 230517-U
Ill. App. Ct.2025Background
- Isacc Smith was convicted of aggravated battery with a firearm after shooting Jayden Harris during a parking lot altercation outside a bar in Kankakee County, Illinois.
- The incident stemmed from a confrontation between two groups, culminating in Harris punching Dajon Smith, after which Isacc Smith fired and shot Harris in the face.
- The core defense was that Smith reasonably believed deadly force was necessary to protect himself or another due to the perceived threat from Harris, whom some testimony claimed had a firearm.
- Key testimony conflicted: only Isacc Smith and Dajon stated Harris had a gun, while others present did not corroborate this, and the initial police interviews suggested otherwise.
- At trial, Smith argued self-defense or defense of another; the jury found him guilty, and he was sentenced to eight years’ imprisonment.
- On appeal, Smith challenged the sufficiency of the evidence negating his defense-of-person claim and alleged prosecutorial errors in closing arguments.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence negating defense of person | Smith did not act reasonably or necessarily in defense, and evidence against him is credible | Smith claimed a reasonable belief that deadly force was necessary to protect himself or others due to Harris's (alleged) possession of a firearm | Evidence was sufficient; jury could reasonably find Smith’s use of deadly force was unjustified |
| Prosecutorial error in closing arguments | State’s statements accurately reflected law and facts; any misstatements were harmless | Smith argued State misstated the law on self-defense, facts on gun possession, and so prejudiced the jury | No prosecutorial error; statements were proper or harmless in context |
Key Cases Cited
- People v. Gray, 2017 IL 120958 (affirmed elements and burdens in claims of defense of person)
- People v. Lee, 213 Ill. 2d 218 (standard for reviewing sufficiency of evidence in self-defense claims)
- People v. Woods, 81 Ill. 2d 537 (circumstances governing reasonable use of force)
- People v. Akis, 63 Ill. 2d 296 (function of trier of fact in assessing credibility)
- People v. Jimerson, 127 Ill. 2d 12 (responsibilities of trier of fact for witness credibility)
- People v. Belknap, 2014 IL 117094 (standard for reversal where evidence is unreasonable or unsatisfactory)
- People v. Evans, 209 Ill. 2d 194 (prosecutorial latitude in closing arguments)
- People v. Williams, 192 Ill. 2d 548 (when improper closing argument warrants reversal)