People v. Wrencher, 959 N.E.2d 693

Indictment charged Wrencher with two counts of aggravated battery for spitting blood on Officer Briggs and digging fingernails into Officer Manzana on June 5, 2007 in Champaign.
Trial in June 2008 resulted in guilty verdicts on both counts; sentencing was seven years’ imprisonment on each count, consecutive.
Wrencher appealed asserting Rule 431(b) voir dire violations and arguing plain/structural error; he also challenged sufficiency of the evidence for the provocation element.
The appellate court initially affirmed; Supreme Court supervisory order directed reconsideration in light of Thompson; court ultimately reaffirmed the prior conclusions.
Evidence at trial showed Briggs was spat upon with blood and saliva, leading to injuries and the use of a spit hood; Manzana testified to fingernail grip and injury.
An alternate juror’s post-trial letter criticized defense questioning; court addressed potential prejudice from Rule 431(b) compliance.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Rule 431(b) compliance in voir dire	Wrencher argues plain/structural error given group questioning and delay.	Wrencher contends inadequate individual inquiry violated Rule 431(b).	No plain or structural error; Rule 431(b) noncompliance did not deny fair trial.
Sufficiency of evidence for provoking/insulting contact	Spitting blood on Briggs constitutes physical contact of insulting or provoking nature.	No evidence Briggs was insulted or provoked by spitting.	Sufficient evidence supported aggravating battery; spitting could be inferred as insulting or provoking.

People v. Thompson, 238 Ill.2d 598 (2010) (Rule 431(b) violation alone not plain error)
People v. Herron, 215 Ill.2d 167 (2005) (plain error requires substantial right denial)
People v. Bannister, 232 Ill.2d 52 (2008) (plain-error review framework)
Jackson v. Virginia, 443 U.S. 307 (1979) (sufficiency standard for evidence)