People v. Craig

2023 IL App (5th) 220526-U
Procedural entryThis page is a short order in People v. Craig. Read the opinion of the Court — 2023 IL App (1st) 200311-U
Appellate Court of Illinois·Decided December 11, 2023·No. 5-22-0526·Unpublished

Opinion

2023 IL App (5th) 220526-U NOTICE NOTICE Decision filed 12/11/23. The This order was filed under text of this decision may be NO. 5-22-0526 Supreme Court Rule 23 and is changed or corrected prior to the filing of a Petition for not precedent except in the

Rehearing or the disposition of IN THE limited circumstances allowed the same. under Rule 23(e)(1). APPELLATE COURT OF ILLINOIS

FIFTH DISTRICT ______________________________________________________________________________

THE PEOPLE OF THE STATE OF ILLINOIS, ) Appeal from the ) Circuit Court of Plaintiff-Appellee, ) Champaign County. ) v. ) No. 20-CF-250 ) ANTOINE D. CRAIG, ) Honorable ) Benjamin W. Dyer, Defendant-Appellant. ) Judge, presiding. ______________________________________________________________________________

JUSTICE BARBERIS delivered the judgment of the court. Presiding Justice Vaughan and Justice Boie concurred in the judgment.

ORDER

¶1 Held: We affirm defendant’s conviction and sentence for first degree murder where the trial court did not abuse its discretion by denying defendant’s motion to bifurcate the guilt and sentencing phases of defendant’s trial, the court’s admission of cell phone and location data records and related testimony was harmless error, and defendant’s natural life sentence was not excessive.

¶2 Following a jury trial in the circuit court of Champaign County, defendant, Antoine D.

Craig, was convicted of first degree murder and sentenced to natural life in prison. Defendant

appeals, arguing that (1) the trial court erred by denying his motion to bifurcate the guilt and

sentencing phases of his trial, (2) the court erred by admitting cell phone and location data records

as self-authenticating business records and by allowing testimony regarding the records, and

(3) his natural life sentence is excessive. For the following reasons, we affirm.

1 ¶3 I. Background

¶4 On February 27, 2020, the State charged defendant by information with four counts of first

degree murder—intentional (720 ILCS 5/9-1(a)(1) (West 2018)) (count I), strong probability (id.

§ 9-1(a)(2)) (count II), knowing (id. § 9-1(a)(1)) (count III), and felony (id. § 9-1(a)(3)) (count

IV)—in connection with the February 23, 2020, death of Tenesha Jenkins. Law enforcement

discovered Jenkins with superficial lacerations and burns to her body, but the pathologist later

determined that her cause of death was smothering by another person. The State filed a notice of

intent to seek a natural life sentence on the basis that the murder was accompanied by exceptionally

brutal and heinous behavior indicative of wanton cruelty as an aggravating factor and as a factor

to be proven beyond a reasonable doubt (730 ILCS 5/5-8-1(a)(1)(b) (West 2018)). The trial court

appointed counsel to represent defendant at defendant’s request, but defendant later hired private

counsel. Defendant requested a jury trial and obtained new counsel once more.

¶5 On April 18, 2022, following discovery and various continuances, defense counsel and the

State filed various pretrial motions. Defense counsel filed a motion to bifurcate the trial pursuant

to Illinois Supreme Court Rule 451(g) (eff. Apr. 8, 2013). Defense counsel requested a proceeding

on the issue of guilt or innocence, and if the State proved defendant guilty by proof beyond a

reasonable doubt, a second proceeding on the issue of whether evidence existed that the murder

was accompanied by exceptionally brutal or heinous behavior indicative of wanton cruelty.

Counsel alleged that defendant “may choose to waive jury for the second proceeding.” According

to counsel, the evidence regarding the sentencing enhancement was irrelevant to the question of

guilt and the undue prejudice from such evidence outweighed its probative value. Counsel sought

to bar testimony and photographs or videos relating to any superficial burns and lacerations or

abrasions on Jenkins’ body. Thus, counsel requested that the trial court bifurcate the trial “to

2 prevent the jury from being unduly prejudiced by certain evidence regarding the crime scene when

determining guilt.”

¶6 Defense counsel also filed a motion to bar unduly prejudicial evidence. Defense counsel

requested that the trial court prohibit the introduction of prejudicial photographs, videos, and

testimony. Counsel alleged that Jenkins’ cause of death was smothering by another person and,

thus, any evidence regarding Jenkins’ burns or lacerations would only inflame and upset the jury

and prejudice them against defendant. Thus, counsel requested that the court prohibit the

introduction of photographs of, or testimony regarding, superficial wounds or burns on Jenkins, as

well as videos, photographs, or testimony regarding any injuries that were not directly related to

smothering by another person as the cause of death.

¶7 The State filed a motion in limine, requesting that the trial court allow the State to present

evidence of self-authenticating business records, pursuant to Illinois Rule of Evidence 902(11)

(eff. Sept. 28, 2018). The State alleged that law enforcement subpoenaed business records from T-

Mobile and Google which were relevant to the case. The State alleged that the records “would be

self-authenticating if they [were] accompanied by a proper certification by a custodian.”

¶8 Also, on April 18, 2022, the trial court addressed the pretrial motions at a hearing. With

regard to the self-authenticating business records, the State argued that it included copies of

certificates prepared by custodians from Google and T-Mobile. According to the State, the

certificates met the requirements of the evidence rules so as to lay the foundation for the

admissibility of the records. Defense counsel objected to the State’s request to admit the business

records but presented no argument on the issue. The court noted its belief that “under Rule 902(11),

admission by way of certified record of a self-authenticating document is permissible.” Thus, the

3 court granted the State’s motion in limine, which sought to admit the T-Mobile and Google account

records.

¶9 With regard to defense counsel’s motion to bifurcate, defense counsel argued that it would

be impossible to argue to a jury that defendant did not commit the murder, but if he did, it was not

brutal or heinous. Counsel noted that she filed the other motion to bar unduly prejudicial evidence

“in tandem with [the motion to bifurcate], because that’s precisely the reason for us to want to

bifurcate this trial.” According to counsel, bifurcation was necessary to bar prejudicial evidence at

the guilt phase that would go towards proving the murder was brutal or heinous. Counsel asserted

that defendant would waive a jury for the element of whether the murder was brutal or heinous.

The State responded that there was a presumption for a unitary trial, that the brutality of the crime

would demonstrate intent to kill, and that all the evidence would be admissible at both phases of

the trial. The trial court noted that it “considered the rule and the comments, and read a few cases

on this issue.” The court agreed with the State, noting that the State planned to present evidence to

show different theories of murder and that the kind of evidence the State intended to introduce

weighed in favor of a unitary trial where the relationship between defendant and the victim was

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People v. Craig, 2023 IL App (5th) 220526-U (Ill. Ct. App. 2023).

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