People v. Teague
2013 IL App (1st) 110349
Ill. App. Ct.2013Background
- Teague murdered his former employer Marcus Hendricks and attempted to murder three police officers while fleeing police.
- He used an AK-47 semiautomatic rifle and fired from about 40 feet away.
- Jurors found Hendricks murdered and three officers were attempted murder victims; Teague personally discharged the firearm.
- Sentencing: 85 years for murder plus a 25-year firearm enhancement, and 50 years for each attempted murder, running concurrently but consecutive to murder, totaling 135 years.
- On appeal Teague challenges sufficiency of intent for the attempted murders and the length of the sentence.
- The court affirms both the convictions and the 135-year sentence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of intent to kill for attempted murder | People argues intent to kill can be inferred from firing at officers. | Teague argues shots did not hit officers or vehicle, lacking intent to kill. | Sufficiency upheld; intent inferred from firing at officers despite misses. |
| Whether the 135-year sentence is an abuse of discretion | People contends the sentence reflects seriousness and aggravation. | Teague contends rehabilitation and mitigating factors were undervalued. | Sentence affirmed; not an abuse of discretion. |
Key Cases Cited
- People v. Green, 339 Ill. App. 3d 443 (2003) (intent to kill may be inferred from surrounding circumstances)
- People v. Parker, 311 Ill. App. 3d 80 (1999) (intent to kill inferred from surrounding circumstances)
- People v. Williams, 165 Ill. 2d 51 (1995) (circumstantial evidence of intent sufficiency rules)
- People v. Ephraim, 323 Ill. App. 3d 1097 (2001) (intent to kill may be inferred from firing at targets)
- People v. Bailey, 265 Ill. App. 3d 262 (1994) (conduct firing toward crowds supports intent to kill)
- People v. Jackson, 232 Ill. 2d 246 (2009) (standard for reviewing sufficiency of evidence; do not substitute judgment)
- Jackson v. Virginia, 443 U.S. 307 (1979) (standard for due process sufficiency of evidence)
- People v. Alexander, 239 Ill. 2d 205 (2010) (reconsideration of rehabilitation vs. seriousness of offense; deference to trial court)
- In re Stern, 124 Ill. 2d 310 (1988) (sufficiency of evidence and state of mind issues)
- People v. Green (duplicate citation), 339 Ill. App. 3d 443 (2003) (see above)