People v. Cobbs

2019 IL App (4th) 170607-U
CourtAppellate Court of Illinois
DecidedNovember 27, 2019
Docket4-17-0607
StatusUnpublished

This text of 2019 IL App (4th) 170607-U (People v. Cobbs) is published on Counsel Stack Legal Research, covering Appellate Court of Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
People v. Cobbs, 2019 IL App (4th) 170607-U (Ill. Ct. App. 2019).

Opinion

NOTICE 2019 IL App (4th) 170607-U This order was filed under Supreme FILED Court Rule 23 and may not be cited NO. 4-17-0607 November 27, 2019 as precedent by any party except in Carla Bender the limited circumstances allowed 4th District Appellate under Rule 23(e)(1). IN THE APPELLATE COURT Court, IL

OF ILLINOIS

FOURTH DISTRICT

THE PEOPLE OF THE STATE OF ILLINOIS, ) Appeal from the Plaintiff-Appellee, ) Circuit Court of v. ) Champaign County NATHAN D. COBBS, ) No. 16CF1185 Defendant-Appellant. ) ) Honorable ) Roger B. Webber, ) Judge Presiding.

JUSTICE KNECHT delivered the judgment of the court. Justices Turner and Harris concurred in the judgment.

ORDER

¶1 Held: The appellate court affirmed, concluding defendant’s various complaints about an audio recording of a jailhouse telephone call and a handwritten jailhouse note were either forfeited or meritless.

¶2 Defendant, Nathan D. Cobbs, appeals from his conviction for aggravated robbery.

On appeal, defendant raises various complaints about two items admitted at his jury trial,

specifically an audio recording of a jailhouse telephone call and a handwritten jailhouse note. We

affirm.

¶3 I. BACKGROUND

¶4 A. Information

¶5 In December 2016, the State charged defendant by information with aggravated

robbery (720 ILCS 5/18-1(b)(1) (West 2014)). The information, as later amended, alleged, on July 5, 2016, defendant, in Champaign County, “knowingly took property from the person or presence

of Jeremy R[.] Davis, namely a backpack and its contents[,] a debit card[,] and a cell phone[,] by

threatening the imminent use of force while indicating by his actions that he [was] armed with a

firearm or other dangerous weapon.”

¶6 B. Motions in Limine

¶7 On May 18, 2017, the State filed a motion in limine seeking to introduce at trial

evidence of defendant’s alleged unlawful use of Davis’s debit card following the commission of

the aggravated robbery as well as defendant’s later attempts to suborn perjury. Specifically, the

State sought to introduce, inter alia, (1) a surveillance video allegedly showing defendant using

Davis’s debit card at a Casey’s General Store in Tuscola on July 5, 2016; (2) a handwritten

jailhouse note which defendant allegedly passed to another inmate on August 30, 2016, while he

was incarcerated in Douglas County on a charge of unlawful possession of a credit card for conduct

relating to this case; and (3) an audio recording of an April 17, 2017, telephone call defendant

allegedly made while incarcerated in Champaign County to his girlfriend, Melissa White. The

State asserted the evidence showing defendant’s unlawful use of Davis’s debit card was relevant

and admissible to show both a common scheme with the robbery and a motive to commit the

robbery. The State asserted the evidence showing defendant’s attempts to suborn perjury was

relevant and admissible to show defendant’s consciousness of guilt. The State attached to its

motion a transcript of the audio recording of the jailhouse telephone call and a copy of the

handwritten jailhouse note.

¶8 On May 19, 2017, the State filed a motion in limine seeking to allow at trial

Champaign police detective Robert Sumption to identify defendant in the surveillance video from

-2- Casey’s General Store pursuant to People v. Thompson, 2016 IL 118667, ¶ 59, 49 N.E.3d 393. The

State provided a detailed review of Thompson and the necessary steps that must be taken prior to

allowing a law enforcement witness to identify a defendant in a video. Specifically, the State noted

defendant should be given the opportunity to examine the witness outside the presence of the jury

to explore the witness’s familiarity with the defendant and any bias or prejudice and to allow the

court to make an informed decision as to whether the probative value of the testimony is

substantially outweighed by the danger of unfair prejudice. The State further noted the court

should, in the event it allowed such testimony, instruct the jury, both before the testimony and in

the final charge to the jury, it need not give any weight to such testimony and should not draw any

adverse inference from the fact the witness is a law enforcement officer. After addressing

Thompson, the State provided a detailed summary of Detective Sumption’s prior interactions with

defendant.

¶9 On May 22, 2017, defendant filed a motion in limine seeking to bar at trial the

introduction of certain statements and discussions contained in the audio recording of the jailhouse

telephone call. Defendant listed multiple statements and discussions from the recording, such as

“[t]he inmate stating that he ‘copped out in Tuscola,’ ” and “[t]he inmate’s and called person’s

discussion of meeting with his lawyer’s investigator.” Defendant argued the listed statements and

discussions were “not relevant” and “unfairly prejudicial.” Defendant requested the trial court to

bar the State from “introducing any evidence of the statements outlined above.”

¶ 10 C. Hearing on Motions in Limine

¶ 11 On May 22, 2017, the trial court held a lengthy hearing on the parties’ motions

in limine. The court and the parties discussed, inter alia, (1) the audio recording of the jailhouse

-3- telephone call, (2) the handwritten jailhouse note, and (3) Detective Sumption’s identification of

defendant in the surveillance video from Casey’s General Store.

¶ 12 1. The Audio Recording of the Jailhouse Telephone Call

¶ 13 As to the audio recording of the jailhouse telephone call, the trial court initially

questioned defense counsel whether he was seeking to bar the entire call or just the specific

statements and discussions outlined in defendant’s motion. Defense counsel responded,

“Judge, there’s, there’s multiple parts of the transcript that

I’m seeking to bar. Well, Judge, I would ask to bar the entire, the

entire transcript. I’ve highlighted some of the issues that I think are

more pertinent than others but—which I’ve outlined in my motion

as to why I think they should be barred.”

¶ 14 The State argued the audio recording of the jailhouse telephone call was relevant to

show (1) defendant was changing his account of what had occurred on the morning of the

aggravated robbery and (2) a consciousness of guilt as defendant was attempting to suborn perjury

from White during the call. The State, acknowledging defendant’s motion largely related to

whether several statements and discussions during the call were unfairly prejudicial, began going

through the transcript of the call and addressing the statements and discussions, conceding at times

certain redactions were necessary.

¶ 15 After the State had addressed some but not all of the statements and discussions in

the transcript, the trial court directed defense counsel to elaborate on his specific complaints.

Defense counsel initially stated:

“Judge, the specific issues I’m objecting to—well, assuming that

-4- the State is able to lay foundation, I think there’s a hearsay issue

with the other person on the other end of the call. I don’t know if the

State is going to be able to prove up who this person is. That witness,

if they’re able to prove up who they think it is, is not unavailable

and they—as far as I know, they have not made any instances or

attempts to bring her in to testify, so I think that is a larger issue with

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Bluebook (online)
2019 IL App (4th) 170607-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-cobbs-illappct-2019.