People v. Anderson

2023 IL App (1st) 211407-U
Procedural entryThis page is a short order in People v. Anderson. Read the opinion of the Court — 2020 IL App (1st) 172583-U
Appellate Court of Illinois·Decided March 21, 2023·No. 1-21-1407·Unpublished

Opinion

2023 IL App (1st) 211407-U No. 1-21-1407 March 21, 2023 SECOND DIVISION

NOTICE: This order was filed under Supreme Court Rule 23 and is not precedent except in the limited circumstances allowed under Rule 23(e)(1). ______________________________________________________________________________ IN THE APPELLATE COURT OF ILLINOIS FIRST DISTRICT ______________________________________________________________________________ THE PEOPLE OF THE STATE OF ILLINOIS, ) Appeal from the ) Circuit Court of Plaintiff-Appellee, ) Cook County. ) ) v. ) No. 13 CR 9646 ) ) Honorable PHILIP ANDERSON, ) Matthew E. Coghlan and ) William B. Raines, Defendant-Appellant. ) Judges Presiding.

JUSTICE HOWSE delivered the judgment of the court. Presiding Justice Fitzgerald Smith and Justice Cobbs concurred in the judgment.

ORDER

¶1 Held: The court erred in denying defendant’s motion for a new trial where a witness’s recantation at a hearing on the motion was newly discovered, material, and likely to change the result on retrial.

¶2 Following a jury trial, defendant Philip Anderson was found guilty of first degree murder

(720 ILCS 5/9-1(a)(1) (West 2012)) and sentenced to 65 years’ imprisonment. At the hearing on

defendant’s motion for a new trial, a witness recanted his trial testimony identifying defendant as No. 1-21-1407

the offender. The trial court denied the motion but, in its oral ruling, misstated certain evidence.

On direct appeal, we remanded for a new hearing on the motion because the court’s justification

for denying relief was “manifestly erroneous.” See People v. Anderson, 2021 IL App (1st) 170658-

U, ¶¶ 47, 52. On remand, the court conducted another hearing and again denied defendant’s motion

for a new trial. 1

¶3 In this appeal, defendant contends that the court erred on remand in denying the motion for

a new trial because, at the first hearing, the State’s primary eyewitness recanted his trial testimony.

Defendant further argues that the admission of a police officer’s testimony at trial regarding

conversations at the scene of the incident was plain error. For the following reasons, we reverse

the denial of defendant’s motion for a new trial and remand the matter for a new trial.

¶4 BACKGROUND

¶5 Defendant was charged with first degree murder and other offenses arising from the

shooting death of Jonathon Hoskins on April 1, 2013. The evidence adduced at trial is detailed in

this court’s first order on direct appeal. See id. Accordingly, we only recount the facts necessary

to resolve the issues presently on appeal. 2

¶6 Defendant’s Trial

¶7 At trial in 2016, Linda Hamer, a United States Postal Service letter carrier, testified that

she was on her route the morning of April 1, 2013, on Eberhart Avenue between 74th Street and

75th Street when she saw a man approach a group of people on the side of the road. The man drew

1 The Honorable Matthew E. Coghlan presided over defendant’s trial and the first hearing on his motion for a new trial. The Honorable William B. Raines presided on remand. 2 The trial exhibits are not included in the record for the present appeal. Descriptions of the exhibits are derived from the prior order on appeal.

-2- No. 1-21-1407

a firearm, discharged it, and fled in the direction from which he came. Hamer could not see the

shooter’s face or identify him, but noted he wore a black hoodie and black jeans.

¶8 Chicago police officer Andre Craig testified that he responded to a call of shots fired on

South Eberhart and spoke with pedestrians to see “if anyone noticed anything” and to identify

potential witnesses. After speaking with individuals, Craig and other officers learned the name of

a potential suspect, “LP,” which Craig also learned was defendant’s nickname. Defense counsel

did not object to this testimony or cross-examine Craig.

¶9 Charles Ambrose testified that he was incarcerated for a parole violation at the time of trial,

had a pending narcotics case, and had been convicted of robbery and unlawful use or possession

of a weapon by a felon. Ambrose stated that he was standing with Hoskins on the sidewalk when

Hoskins was shot. Ambrose heard a noise “[l]ike a firecracker” and saw Hoskins fall from 10 to

15 feet away. Ambrose did not see anyone leave the scene or approach Hoskins.

¶ 10 Ambrose acknowledged speaking with officers at the police station, but denied telling them

that he was with Hoskins and another person in front of a building on South Eberhart. Ambrose

denied telling police that he saw LP shoot Hoskins, and testified instead that he did not know LP.

Ambrose also denied telling officers that he saw a person walking north on the west side of the

street with a dark hoodie pulled over his head. He denied telling police that when the person

approached, he “clearly” saw it was LP, or that LP walked toward him, “raised his arm and shot

[Hoskins] in the back of the head.” He denied telling police that LP then turned, ran southbound

down Eberhart, and westbound through the north alley of 75th. Additionally, he denied telling

police that he had seen LP driving north on Eberhart from 75th in a tan Lincoln Continental

approximately three days before the incident.

-3- No. 1-21-1407

¶ 11 Ambrose further testified that he viewed a photo array, but informed officers that he did

not recognize anyone in the array. Ambrose acknowledged signing the photo array, but denied

writing “LP, shooter” on it. Ambrose identified his signed photo array advisory form and the photo

array with one photograph annotated “April 1, 2013, LP shooter, 8:29 p.m.” in his handwriting

with his signature. Ambrose testified that an officer told him to write that.

¶ 12 Ambrose also gave a statement, transcribed by an assistant State’s Attorney (ASA).

Ambrose identified his signature on the written statement, but did not know if the attached

photograph, which he signed, depicted LP. Ambrose denied telling police officers that he was not

under the influence of marijuana or alcohol at the time he gave his statement, and did not recall

stating that he gave his statement freely and voluntarily.

¶ 13 Ambrose testified that he told a grand jury that he stood on the sidewalk with Hoskins, but

denied stating that he saw someone approach the group wearing a black hoodie with the hood

raised. Ambrose denied testifying that he knew the person was LP because he had seen LP in a

vehicle several days earlier. Ambrose agreed that he testified that he heard two shots and saw

Hoskin’s body drop to the ground but did not remember testifying that he saw LP stand “a step”

behind Hoskins and extend his arm before the shots were fired and then walk away. Ambrose did

not recall testifying about viewing a photo array. Further, Ambrose was high “off pills,” namely

Ecstasy, “around” the time he testified before the grand jury. Ambrose did not recall telling the

grand jury that his statement to police was the same as his grand jury testimony and that he testified

freely and voluntarily. Ambrose also did not recall whether he signed a photograph of LP before

the grand jury.

¶ 14 On cross-examination, Ambrose stated that he was not under arrest when he spoke to police

and did not believe he was a suspect. Nor did Ambrose believe he was a suspect when he testified

-4- No. 1-21-1407

before the grand jury. Ambrose did not write the statement to police; rather, he signed all five

Free access — add to your briefcase to read the full text and ask questions with AI

People v. Anderson, 2023 IL App (1st) 211407-U (Ill. Ct. App. 2023).

2023 IL App (1st) 211407-U (People v. Anderson) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

People v. Williams
692 N.E.2d 723 (Appellate Court of Illinois, 1998)
People v. Smith
685 N.E.2d 880 (Illinois Supreme Court, 1997)
People v. Anderson
2021 IL App (1st) 170658-U (Appellate Court of Illinois, 2021)