People v. Ward
2025 IL App (1st) 232370-U
Ill. App. Ct.2025Background
- Candace Ward was charged with criminal trespass after entering Longfellow Elementary School in Oak Park, Illinois, despite a prior no-trespass notice.
- The no-trespass notice was issued due to previous instances of Ward’s threatening or profane behavior toward staff, and required her to give 48 hours’ notice and receive permission before entering school grounds (except for child drop-off/pick-up).
- The no-trespass notice was conveyed to Ward multiple times: by mail and email, by an additional email, and via hand-delivery.
- On September 14, 2022, Ward attended a school event (curriculum night) without proper notification or permission, during which police responded and removed her from the premises.
- At trial, Ward argued the State failed to prove she received notice and thus lacked the required knowledge for conviction; she was found guilty and sentenced to six months’ supervision.
- Ward appealed, challenging the sufficiency of the State’s evidence regarding her receipt and awareness of the no-trespass notice.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the State proved Ward received adequate notice | Testimony and multiple delivery methods showed notice | Evidence did not show Ward actually received or read the notices | Sufficient evidence supported finding Ward had notice |
| Sufficiency of circumstantial evidence for knowledge | Ward’s receipt of other emails infers awareness | Insufficient circumstantial evidence that Ward was consciously aware | Inference of knowledge from notice and email was proper |
| Validity of Starks Turner's hand-delivery testimony | Starks Turner credibly testified notice was hand-delivered | Testimony was vague as to time/place and thus unreliable | Fact-finder's credibility decision was not disturbed |
| Effect of school’s general event email invitation | Did not supersede no-trespass order | Email invitation negated effect of prior no-trespass notice | Invitation did not override no-trespass notice |
Key Cases Cited
- People v. Beauchamp, 241 Ill. 2d 1 (Ill. 2011) (standard for reviewing sufficiency of evidence in criminal cases)
- People v. Milka, 211 Ill. 2d 150 (Ill. 2004) (credibility determinations lie with trial court)
- People v. Smith, 185 Ill. 2d 532 (Ill. 1999) (testimony of a single credible witness is sufficient for conviction)
- People v. Wheeler, 226 Ill. 2d 92 (Ill. 2007) (approach to circumstantial evidence and reasonable doubt)
- People v. Galarza, 2023 IL 127678 (Ill. 2023) (reasonable inferences from circumstantial evidence are proper)