People v. Dawson

2025 IL App (1st) 190422
CourtAppellate Court of Illinois
DecidedJune 13, 2025
Docket1-19-0422
StatusUnpublished

This text of 2025 IL App (1st) 190422 (People v. Dawson) 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. Dawson, 2025 IL App (1st) 190422 (Ill. Ct. App. 2025).

Opinion

2025 IL App (1st) 190422-UB

FIFTH DIVISION June 13, 2025

No. 1-19-0422

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 JUDICIAL DISTRICT

THE PEOPLE OF THE STATE OF ILLINOIS, ) Appeal from the ) Circuit Court of Plaintiff-Appellee, ) Cook County. ) v. ) No. 17 CR 11401 ) EARL DAWSON, ) Honorable ) James B. Linn, Defendant-Appellant. ) Judge Presiding.

PRESIDING JUSTICE MIKVA delivered the judgment of the court. Justices Oden Johnson and Mitchell concurred in the judgment.

ORDER

¶1 Held: (1) defendant’s trial counsel was not ineffective for stipulating to his prior qualifying felony convictions as predicates for the armed habitual criminal offense; (2) the trial court did not abuse its discretion in admitting police course-of- investigation testimony; and (3) defendant was not subject to improper double enhancement and his sentence was not an abuse of discretion. ¶2 Following a jury trial, Earl Dawson was convicted of the offense of being an armed habitual

criminal (AHC) (720 ILCS 5/24-1.7(a), (b) (West 2016). On direct appeal, Mr. Dawson

successfully argued, with one justice dissenting, that the State failed to prove beyond a reasonable

doubt that he had the prior qualifying criminal convictions necessary to sustain his AHC No. 1-19-0422

conviction. As a result, we reduced his conviction to the lesser-included offense of aggravated

unlawful use of a weapon (AUUW) (720 ILCS 5/24-1.6 (West 2016)) and remanded for

resentencing. People v. Dawson, 2022 IL App (1st) 190422, ¶ 67.

¶3 On May 29, 2024, in the exercise of its supervisory authority, our supreme court directed

this court to (1) vacate our September 30, 2022, judgment in this case, (2) consider the effect of

the supreme court’s subsequently decided opinion in People v. Gray, 2024 IL 127815, “on the

issue of whether the State proved beyond a reasonable doubt that Mr. Dawson had the requisite

predicate adult convictions necessary to sustain his [AHC] conviction,” and (3) “determine if a

different result [wa]s warranted.” People v. Dawson, No. 129136 (Ill. May 29, 2024).

¶4 After vacating our prior judgment in this appeal, we granted the parties leave to each file a

supplemental brief on the issues presented by the supreme court’s supervisory order. In response,

Mr. Dawson filed a brief in which he concedes, for purposes of this appeal, that at trial the State

had “presented sufficient evidence to sustain [Mr. Dawson’s] [AHC] conviction” based on his

counsel’s stipulation. However, Mr. Dawson argues that “a different outcome [i]s [not] warranted”

because counsel was ineffective for stipulating to “qualifying” prior felony convictions. In

response, the State argues that consideration of ineffective assistance exceeds the supreme court’s

mandate and, if we decide to reach this argument, Mr. Dawson’s claim that the stipulation was

ineffective assistance is without merit.

¶5 For the following reasons, we reject Mr. Dawson’s argument that his lawyer’s stipulation

that he had qualifying prior convictions was ineffective assistance of counsel. We also incorporate

our determination from our initial decision that the trial court did not abuse its discretion in

allowing evidence about the police course-of-investigation. Finally, we reject Mr. Dawson’s

argument that the court’s 12-year sentence rested on improper sentencing factors or was an abuse

2 No. 1-19-0422

of discretion. Because of our resolution of the merits of this appeal, we deny Mr. Dawson’s motion

for immediate release, which we took with the case.

¶6 I. BACKGROUND

¶7 Prior to trial, Mr. Dawson moved to exclude the officers’ course-of-investigation testimony

about why they were in the area and why they chased him. Defense counsel argued:

[“DEFENSE COUNSEL]: So I’m just asking for a limiting testimony. I know that

officers have to testify why they were in the area in order for it to make sense.

THE COURT: They have to show why they went to a location and why they did

certain things and why they chased somebody and why they chased him all the way in the

house and looking for certain things. That’s all fair game.

*** I will tell the jury that he’s not accused of any shooting, that he’s not charged

with any shooting, that the only reasons they are hearing that is not for the truth of the

matter asserted, but just to indicate why the police were—say that they were at a location

and say that they acted in a certain way. So, I will give a limiting instruction as to that.

[DEFENSE COUNSEL]: And part of my motion is that none of it should come out.

It should just be that the officers were told to go in the area and saw him running. I don’t

believe any shooting is admissible.

THE COURT: Well, to say that—to have a complete vacuum as to why the police

are chasing somebody from the street into a house wouldn’t make any sense.”

¶8 The trial court found that, “[o]therwise,” without this information, “it just seems like [the

police] are out there randomly barging into people’s homes for no reason whatsoever.” Instead,

the trial court stated that it would provide a limiting instruction.

¶9 The trial occurred on November 8, 2018. The evidence at trial showed that police officers

3 No. 1-19-0422

responded to a radio dispatch on July 20, 2017, about a shooting in the area. The dispatch described

the subject as a “male black with a red shirt running in an alley.” After driving to the area, one of

the officers observed Mr. Dawson running from an alley and observed that he fit the description

provided in the dispatch. Chasing Mr. Dawson on foot, the officer followed him into a residence

where the officer observed Mr. Dawson pull a dark object from his waistband and place it on top

of a laundry basket behind a door. After Mr. Dawson was detained and handcuffed, the police

recovered two firearms from the top of the laundry basket: a Smith & Wesson 9-mm handgun and

a Jennings 9-mm handgun.

¶ 10 Over Mr. Dawson’s objection, the trial court granted the State’s request to certify two

police officers as experts in fingerprint analysis. One of the officers testified that an inked

fingerprint card from Mr. Dawson shared 20 characteristics with the ridge impressions recovered

from the grip of the Jennings handgun. The expert testified that eight characteristics in the same

relative positions generally indicates that the prints came from the same individual.

¶ 11 The parties stipulated that Mr. Dawson had previously been convicted of two qualifying

felony offenses. Defense counsel agreed to several other stipulations, including to the proposed

testimony of the officer who recovered the firearms from “a laundry bag,” to a “proper chain of

custody” for the firearms, and to the fingerprints taken from Mr. Dawson. Mr. Dawson did not

testify or present any evidence.

¶ 12 During the trial, the trial court provided the jury with a limiting instruction stating that Mr.

Dawson was not accused of a shooting and that there was “no evidence” that Mr. Dawson “was

involved in” a shooting:

“THE COURT: Let me make it clear, Ladies and Gentlemen. This is about—

receiving a call about shots, that’s not for the truth of the matter asserted. That’s to indicate

4 No.

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2025 IL App (1st) 190422, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-dawson-illappct-2025.