People v. Wilson
2017 IL App (1st) 143183
| Ill. App. Ct. | 2017Background
- On Oct. 27, 2011, Kelli O’Laughlin was found dead in her home; a red knit hat with a rock was recovered from the dining room floor.
- Officer Sachtleben recovered the hat, photographed it, and later took a buccal swab from defendant John Wilson on Nov. 2, 2011.
- Illinois State Police scientists swabbed and cut a portion of the hat, performed PCR/STR analysis, and identified a major male DNA profile that matched Wilson.
- FBI Agent Joseph Raschke performed historical cell site analysis (HCSA) using call logs, concluding defendant’s and victim’s phones were regularly in the same general areas on Oct. 27–29, 2011.
- At trial the State proceeded on intentional, knowing, and felony-murder theories; the court submitted a single general verdict form for first degree murder.
- The jury convicted Wilson of first degree murder, armed robbery, home invasion, and residential burglary; he received an aggregate 160-year sentence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility of red hat/DNA — chain of custody/foundation | State: hat identified at trial by recovering officer; evidence in sealed bags; DNA testing properly performed. | Wilson: State failed to establish chain of custody for the hat; DNA evidence lacked foundation. | Court: Foundation adequate — hat was readily identifiable; no plain error shown; forfeiture applies. |
| Expert DNA methodology disclosure (STR) / confrontation | State: expert may give opinion without disclosing underlying data on direct; basis available on cross‑examination under Rule 705/Wilson. | Wilson: expert failed to explain STR methodology, depriving him of ability to cross‑examine (Confrontation/foundation). | Court: admissible; experts need not disclose bases on direct; Wilson/Williams/Rule 705 govern; plain error rejected. |
| Historical cell site analysis (HCSA) — Frye hearing | State: HCSA here was record reading and plotting, not novel scientific evidence; Frye not implicated. | Wilson: HCSA is scientific and required Frye validation of methodology. | Court: HCSA testimony was not Frye‑type scientific evidence; Frye hearing unnecessary; counsel not ineffective for failing to request one. |
| Jury verdict form (single general verdict for murder) — ineffective assistance | State: no objection at trial; counsel strategy plausible given defense of misidentification. | Wilson: counsel ineffective for not requesting separate verdict forms per People v. Smith. | Court: Smith limited to cases where request for separate forms was denied; here no such denial and strategic choice plausible; claim fails. |
Key Cases Cited
- People v. Woods, 214 Ill. 2d 455 (Ill. 2005) (chain‑of‑custody plain‑error standard; rare "complete breakdown" required to excuse forfeiture)
- People v. Smith, 233 Ill. 2d 1 (Ill. 2009) (requiring separate verdict forms where jury findings affect sentencing and a request was made)
- People v. Williams, 238 Ill. 2d 125 (Ill. 2010) (expert testimony: basis for opinion is subject to cross‑examination under Rule 705)
- Wilson v. Clark, 84 Ill. 2d 186 (Ill. 1981) (adopting rule that expert may state opinion without prior disclosure of underlying facts; cross‑examination may probe basis)
- Frye v. United States, 293 F. 1013 (D.C. Cir. 1923) (scientific evidence admissible only if methodology has general acceptance)
- People v. Safford, 392 Ill. App. 3d 212 (Ill. App. Ct. 2009) (latent‑print expert testimony challenged for failing to disclose basis; discussed and declined to be followed here)
- People v. Piatkowski, 225 Ill. 2d 551 (Ill. 2007) (plain‑error framework for noticing unpreserved errors)