2025 IL App (5th) 230036
Ill. App. Ct.2025Background
- Wiley was convicted of aggravated battery and sentenced to 24 months’ probation in Champaign County case No. 22-CF-247.
- The charges stemmed from a March 1, 2022 stabbing of Lavell Fleming during a confrontation at Ulta Beauty, involving Rona Wiley-Hillsman and a group.
- The defense asserted self-defense; weapons included a knife and a machete; Lavell and Rona were involved in the incident and attempted to separate the parties.
- A cell phone video and weapons were admitted; the video depicted Lavell restraining Wiley, Rona with a machete, and Wiley stabbing Lavell twice.
- The State published portions of the body-camera video; the jury deliberated after arguments on self-defense and related issues.
- On appeal, the Illinois Appellate Court reversed, concluding the State failed to prove Wiley did not act in self-defense and addressing contemporaneous handling of the video and jury instructions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the State proved Wiley did not act in self-defense | Wiley contends the State failed to disprove self-defense beyond a reasonable doubt. | Wiley argues she was not the initial aggressor and that the force used was necessary to defend against imminent danger. | Self-defense not disproved; conviction reversed. |
| Whether the initial aggressor instruction should have been given | State sought IPI 24-25.09; argues Wiley was initial aggressor. | Wiley argues no evidence supports initial aggressor status; instruction misleads self-defense analysis. | Instruction improperly favored State; reversal of conviction on self-defense grounds. |
| Whether the jury was restricted to a single viewing of video evidence | State presented portions of the video during trial and again during deliberations. | Limiting viewing deprived Wiley of full context and credibility assessment of the video. | Limitation of video viewing was improper; contributes to reversal. |
| Whether prosecutorial misconduct occurred in closing arguments | Prosecutor misstated evidence and gave personal opinions about Wiley’s credibility and self-defense. | State argues no misconduct; trial record shows argument within bounds. | Misconduct found; contributes to reversal. |
| Whether trial counsel was ineffective for failing to object to instructions and misconduct and viewing limits | Counsel did not object to jury instructions, alleged misconduct, and single-view policy. | Counsel’s failures prejudiced Wiley by permitting flawed instructions and evidentiary handling. | Ineffectiveness established; reversal of conviction. |
Key Cases Cited
- People v. Lee, 213 Ill. 2d 218 (Ill. 2004) (self-defense elements burden on State when raised)
- People v. Jeffries, 164 Ill. 2d 104 (Ill. 1995) (self-defense burden and element analysis)
- People v. Banks, 227 Ill. App. 3d 462 (Ill. App. Ct. 1992) (initial aggression and provocation distinctions in self-defense)
- People v. Belpedio, 212 Ill. App. 3d 155 (Ill. App. Ct. 1991) (retaliation and provocation considerations in self-defense)
- People v. Baggett, 115 Ill. App. 3d 924 (Ill. App. Ct. 1983) (disproportionate force and non-retaliatory use of force)
- People v. Salazar, 126 Ill. 2d 424 (Ill. 1989) (armed presence and aggression implications in self-defense)
- People v. Johnson, 2 Ill. 2d 165 (Ill. 1954) (objective vs. subjective belief standard in self-defense)