People v. Ybarra
2022 IL App (1st) 191076-U
| Ill. App. Ct. | 2022Background
- Defendant Matthew Ybarra was convicted after a bench trial of misdemeanor domestic battery (March 23, 2018) and sentenced to one year of conditional discharge.
- Charged conduct: according to the victim Salina Bone, during an overnight incident Ybarra punched her lip, pushed her, grabbed her neck twice (choking her until she vomited), and made threats; photographs showed lip injury and a police detective observed an abrasion on her lip when she reported the incident.
- The State moved under 725 ILCS 5/115-7.4 to admit evidence of three prior domestic-violence incidents between late Dec. 2017 and March 2018; the court admitted two (Dec./Jan. and Feb. incidents) because they were proximate and factually similar (both involved choking) and excluded a March 15 incident.
- Trial evidence included Salina’s testimony, corroborating photos, testimony from a witness (Tatiana Hill) who saw a February choking, police testimony about the report, and defendant’s denial (he said Salina injured him and he never choked or struck her).
- On appeal Ybarra argued (1) insufficiency of the evidence (victim testimony implausible/uncorroborated and delayed reporting) and (2) erroneous admission of prior-act evidence as speculative and unduly prejudicial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of the evidence to prove domestic battery | Salina’s credible testimony, photographs of injury, and police observation corroborate bodily harm | Victim’s account was implausible, delayed reporting and post-incident calls undermined credibility | Affirmed — viewed in light most favorable to State, a rational trier of fact could find bodily harm beyond a reasonable doubt |
| Admissibility of prior domestic-violence acts under §115-7.4 | Prior incidents were proximate, factually similar (choking) and relevant to propensity/intent; probative value outweighed prejudice | Prior acts were speculative, uncorroborated, different in cause/severity and highly prejudicial | Affirmed — trial court did not abuse discretion; court balanced probative value vs. undue prejudice and limited admission to necessary details |
Key Cases Cited
- People v. Cunningham, 212 Ill.2d 274 (2004) (due-process/reasonable-doubt standard)
- Jackson v. Virginia, 443 U.S. 307 (1979) (standard for sufficiency review)
- In re Winship, 397 U.S. 358 (1970) (proof beyond a reasonable doubt requirement)
- People v. Dabbs, 239 Ill.2d 277 (2010) (statutory framework for admitting prior domestic-violence acts under §115-7.4)
- People v. Illgen, 145 Ill.2d 353 (1991) (common-law other-crimes limits and purposes)
- People v. Donoho, 204 Ill.2d 159 (2003) (deference to trial court on admissibility where prior act is probative and similar)