People v. Thompson, 21 N.E.3d 1

Thompson was charged with illegal procurement of anhydrous ammonia and tampering with equipment under the Methamphetamine Control and Community Protection Act.
The evidence included surveillance video and still images; several officers testified about identifying Thompson from those images.
A motions in limine challenged lay opinions identifying Thompson from surveillance; the trial court denied it.
Two witnesses testified to identifying Thompson from a still image; others testified about the surveillance video.
The jury found Thompson guilty on both counts and he was sentenced to 18 years’ imprisonment.
The appellate court reversed and remanded, finding improper lay identification testimony and prejudicial police procedure, undermining the verdict.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was identification testimony from law enforcement improper?	Thompson	Thompson	Yes; improper under Starks; testimony invaded the jury's function.
Did cumulative, improperly admissible identifications prejudice the jury?	State	Thompson	Yes; multiple bare conclusions tainted the verdict and undermined confidence.
Did the police-procedure testimony unduly emphasize investigation over proof?	State	Thompson	Yes; testimony about prior dealings and investigation steps was prejudicial.

People v. Starks, 119 Ill. App. 3d 21 (1983) (framework for admissibility of lay identification testimony)
People v. Owens, 394 Ill. App. 3d 147 (2009) (id framework and limits for non firsthand identification)
People v. Sykes, 2012 IL App (4th) 111110 (2012) (limits on lay opinion on ultimate issue and identification)
United States v. Calhoun, 544 F.2d 291 (6th Cir. 1976) (federal rule interpretation guiding Illinois law on Rule 701)
People v. Byrd, 43 Ill. App. 3d 735 (1976) (limits on admissibility of investigative testimony to explain steps)