People v. Williams
2017 IL App (1st) 142733
| Ill. App. Ct. | 2017Background
- On April 22, 2008 five people were shot to death in a Chicago residence; defendant Torolan Williams was arrested June 9, 2008 and later tried for five counts of first‑degree murder and one count of armed robbery.
- While in custody on June 9, Williams requested to make multiple phone calls (denied), was Mirandized several times, attempted to flee briefly, and before invoking counsel at 6:28 p.m. made statements admitting he acted as a lookout and implicated Michael King.
- The trial court suppressed statements made after Williams invoked counsel and those at the hospital when an attorney was denied access, but admitted statements made earlier in custody as voluntary.
- The State sought to introduce historical cell‑site records for co‑defendants Michael King and Arthur Brown; an FBI agent mapped tower connections but the court limited testimony to which towers connected (not precise phone locations) and denied a Frye hearing.
- Arthur Brown testified for the State describing involvement in the robbery/murders and statements by Williams; the cell‑site evidence was used to corroborate witness timing/location testimony.
- The jury convicted Williams on all counts; he was sentenced to life on the murders and 20 years for armed robbery and appealed, raising suppression, Frye, prosecutorial comments about sentencing, alleged violation of the court’s cell‑tower limits, and the judge’s reference to some verdict forms as “guilty forms.”
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Voluntariness / suppression of pre‑invocation statements | Statements were voluntary; Miranda warnings given multiple times; totality supports admission | Denial of repeated phone requests (to check on sick newborn) and custody conditions coerced statements; statutory right to phone (725 ILCS 5/103‑3) violated | Court affirmed: pre‑invocation statements voluntary under totality; statute violation not shown to require suppression |
| Frye hearing for cell‑site mapping | Plotting call‑detail records to towers is not novel scientific evidence requiring Frye; proof goes to weight not admissibility | Technique is unreliable/novel; Frye hearing required to test general acceptance | Court affirmed denial of Frye hearing: cell‑site plotting not novel scientific technique; admissible for showing vicinity only |
| Prosecutorial use of sentencing discussion in recorded interrogation | Brief sentencing exchange in video did not materially prejudice verdict; court instructed jury to disregard and sentencing is judge's province | Inclusion of discussion about sentence/death penalty was prejudicial and improper | Court affirmed: comments were not substantially prejudicial, jury was admonished, and remarks did not materially affect verdict |
| Judge's remark calling some verdict forms “guilty forms” | State: remark was an inadvertent misspeak and jury was properly instructed on presumption of innocence and burden of proof | Defendant: remark intimated judge’s opinion and denied fair trial; plain error | Court affirmed: viewed in context, court repeatedly stated neutrality and instructed properly; remark not clear/obvious prejudicial error |
Key Cases Cited
- Miranda v. Arizona, 384 U.S. 436 (1966) (warnings and custodial interrogation protections)
- Jackson v. Denno, 378 U.S. 368 (1964) (involuntary confessions and due process suppression rule)
- Haynes v. Washington, 373 U.S. 503 (1963) (coercive custodial conditions can render confessions involuntary)
- Frye v. United States, 293 F. 1013 (D.C. Cir. 1923) (general‑acceptance test for novel scientific evidence)
- People v. Richardson, 234 Ill. 2d 233 (2009) (totality of circumstances test for voluntariness)
- People v. McKown, 236 Ill. 2d 278 (2010) (Frye limited to new or novel scientific principles)
- In re Commitment of Simons, 213 Ill. 2d 523 (2004) (admissibility standard for scientific expert evidence)
- Donaldson v. Central Illinois Public Service Co., 199 Ill. 2d 63 (2002) (judicial notice of general acceptance when appropriate)
- People v. Sutton, 316 Ill. App. 3d 874 (2000) (prosecutorial remarks about sentencing can be reversible if materially prejudicial)