People v. Strong
2025 IL App (1st) 240793-U
Ill. App. Ct.2025Background
- Defendant Andre Strong was charged after an incident in which he pursued, rear-ended, and discharged a firearm toward a vehicle containing siblings Jordan and Jorian Brown on November 22, 2018.
- Following a bench trial, Strong was found guilty of reckless discharge of a firearm and sentenced to 24 months’ probation.
- At trial, the prosecution's witnesses testified that the defendant fired at the car while unprovoked, whereas the defendant claimed he fired a warning shot at the ground because he believed he was threatened.
- Defendant initially denied to police that he fired a gun, later admitting to firing a shot after being confronted with evidence; he hid both his car and the firearm, actions which the court viewed as indicating consciousness of guilt.
- The trial court ultimately found the defendant’s use of force was neither reasonable nor necessary and that he did not act in self-defense.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of the evidence for reckless discharge | Defendant was reckless and not justified in using force | Strong acted in self-defense, believing a threat was imminent | Evidence sufficient; conviction affirmed |
| Justification/Self-defense | No credible threat justified use of deadly force | Believed (though not actually threatened) that danger existed | No reasonable basis for self-defense |
| Weighing witness credibility | Prosecution witnesses testified credibly | Strong's account conflicts; should be believed over prosecution | Trial court found prosecution credible |
| Impact of defendant's post-incident conduct | Concealment shows consciousness of guilt | Hiding car/firearm was driven by panic, not guilt | Conduct supports lack of justification |
Key Cases Cited
- People v. McLaurin, 2020 IL 124563 (sets standard for sufficiency of evidence in criminal cases)
- People v. Siguenza-Brito, 235 Ill. 2d 213 (outlines trier of fact’s role in witness credibility and evidence weight)
- People v. Jackson, 2020 IL 124112 (addresses reasonable inferences from evidence)
- People v. Givens, 237 Ill. 2d 311 (all reasonable inferences from record in favor of prosecution)
- People v. Bradford, 2016 IL 118674 (conviction only overturned if evidence is unreasonable or unsatisfactory)
- People v. Murillo, 225 Ill. App. 3d 286 (trier of fact can reject defendant’s testimony in favor of others)