People v. Staake
102 N.E.3d 217
| Ill. | 2017Background
- Defendant Jared Staake was initially charged by information with second-degree murder for stabbing Michael Box; he later disclosed intent to assert self-defense.
- The State moved to amend the information to charge first-degree murder; it filed two amendments charging first-degree murder under different subsections (knowledge and strong probability). Defense counsel said the amendments did not impair trial preparation.
- The trial court granted the State’s motion in limine to bar defense evidence/argument that Box’s refusal of medical treatment was an intervening cause, but allowed such proof if the defense made an offer of proof outside the jury’s presence.
- At trial, evidence showed defendant stabbed Box, Box received initial hospital treatment and left, later returned, and died two days after the stabbing; the medical examiner testified death was from the stab wound (peritonitis/septic shock).
- Defense conceded causation to the jury in closing; jury convicted Staake of second-degree murder and he was sentenced to 18 years’ imprisonment.
- On appeal and in the Illinois Supreme Court, Staake challenged (1) whether amendment to first-degree murder violated the statutory speedy-trial rule (Williams rule/compulsory joinder), and (2) exclusion of evidence/argument about intervening cause without an offer of proof. He also argued ineffective assistance for failure to raise the speedy-trial claim.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether amendment from second-degree to first-degree murder was a “new and additional charge” for speedy-trial purposes (Williams rule) | The State: charges allege the same conduct; original information gave notice so delays attributable to defendant on original charge apply to amended charge. | Staake: first-degree murder is substantively different (different subsection/mental state and greater penalty), so prior delays shouldn’t be charged to him. | Court held not new/additional; elements and conduct were the same; earlier delays attributable to defendant applied to amended charge. |
| Whether counsel was ineffective for failing to raise a speedy-trial objection | The State: no prejudice because no speedy-trial violation occurred. | Staake: counsel’s failure to raise the statutory speedy-trial claim was deficient and prejudicial. | Court held no ineffective assistance because no statutory speedy-trial violation occurred. |
| Whether trial court erred in excluding evidence/argument that victim’s refusal of treatment was intervening cause without an offer of proof | The State: exclusion was conditional; defense could present evidence if it made an offer of proof showing factual basis. | Staake: barring evidence/argument on causation deprived him of the ability to challenge causation. | Court held issue forfeited—trial court did not categorically bar causation proof but required an offer of proof; defense never proffered and conceded causation at trial. |
Key Cases Cited
- People v. Williams, 94 Ill. App. 3d 241 (Williams rule on relating subsequent charges to original indictment)
- People v. Phipps, 238 Ill. 2d 54 (explains Williams rule and focus on whether original charge gave adequate notice)
- People v. Jeffries, 164 Ill. 2d 104 (discusses mental-state elements of first- and second-degree murder)
- People v. Domagala, 2013 IL 113688 (presumption that death from accused’s act is controlling absent a completely unrelated intervening cause)
- People v. Wilmington, 2013 IL 112938 (explains when second-degree murder instruction must be given in a first-degree murder prosecution)