People v. Williams, 210 N.E.3d 1207

Defendant Travis J. Williams was convicted by a jury of three counts of predatory criminal sexual assault of a child and three counts of criminal sexual assault based on testimony from two victims (his daughter K.W. and stepdaughter H.S.).
The State had pretrial leave to introduce other-crimes testimony and identified additional potential witnesses (A.R., L.M., and the victims’ mother Patti), but at trial called only K.W., H.S., and an expert (Johanna Hager).
Defense closing emphasized lack of corroboration and argued the State could easily have called A.R. and K.W.’s wife to corroborate; defense suggested those witnesses would support an alternative explanation and criticized the State’s decision not to call them.
In rebuttal the prosecutor (1) told jurors the defense had subpoena powers too (defense objected and the court overruled) and (2) stated, without objection, that hearsay is “something that’s said outside of court” and implied the State could not have called A.R. or K.W.’s wife because of the hearsay rule.
The appellate court reversed, finding the unobjected-to hearsay remark was plain error in a closely balanced case and remanded for a new trial; the Illinois Supreme Court granted leave and reversed the appellate court, affirming the trial convictions.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Williams)	Held
Whether prosecutor’s comment that the defense had subpoena powers improperly shifted burden (objected)	The remark was a proper, invited response to defense argument that the State failed to call obvious witnesses; both sides have subpoena power.	The comment improperly shifted burden to defendant and was not invited because family witnesses were less accessible to defense.	Held: Not improper; invited by defense, accurate, brief, and not substantially prejudicial; trial court did not abuse discretion.
Whether prosecutor’s unobjected-to hearsay explanation in rebuttal was reversible plain error	The hearsay remark was an acceptable, concise description of the rule and a reasonable response to defense claims; even if imperfect, it was not clearly erroneous or prejudicial because the evidence was not closely balanced.	The prosecutor misstated hearsay law and implied the defense knew testimony was inadmissible; that misstatement prejudiced the verdict and warranted reversal under plain-error doctrine.	Held: No clear or obvious error; truncated definition captured the core rule and was invited by defense; evidence was not closely balanced, so first-prong plain error was not shown.

People v. Piatkowski, 225 Ill. 2d 551 (explaining the "clear or obvious" threshold for plain error)
People v. Herron, 215 Ill. 2d 167 (describing the two-prong plain-error doctrine and its purpose to safeguard fair trials)
People v. Naylor, 229 Ill. 2d 584 (example of a closely balanced case driven by competing credible accounts)
People v. Runge, 234 Ill. 2d 68 (two-step inquiry for prosecutorial closing-argument errors)
People v. Kliner, 185 Ill. 2d 81 (permitting prosecutor to respond when defense attacks State for not calling witnesses with equal access)
People v. Henderson, 142 Ill. 2d 258 (discussing prejudice standards for prosecutorial argument)
People v. Sebby, 2017 IL 119445 (procedural preservation and plain-error framework)
People v. Macri, 185 Ill. 2d 1 (substantial-prejudice standard for objected-to improper comments)