People v. Dewey

2025 IL App (3d) 230611, 258 N.E.3d 139
CourtAppellate Court of Illinois
DecidedFebruary 26, 2025
Docket3-23-0611
StatusPublished

This text of 2025 IL App (3d) 230611 (People v. Dewey) 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. Dewey, 2025 IL App (3d) 230611, 258 N.E.3d 139 (Ill. Ct. App. 2025).

Opinion

2025 IL App (3d) 230611

Opinion filed February 26, 2025 ____________________________________________________________________________

IN THE

APPELLATE COURT OF ILLINOIS

THIRD DISTRICT

THE PEOPLE OF THE STATE OF ) Appeal from the Circuit Court ILLINOIS, ) of the 12th Judicial Circuit, ) Will County, Illinois, Plaintiff-Appellant, ) ) Appeal No. 3-23-0611 v. ) Circuit No. 16-CF-2230 ) CHRISTOPHER D. DEWEY, ) Honorable ) Vincent F. Cornelius, Defendant-Appellee. ) Judge, Presiding. ____________________________________________________________________________

JUSTICE HOLDRIDGE delivered the judgment of the court, with opinion. Justices Peterson and Anderson concurred in the judgment and opinion. ____________________________________________________________________________

OPINION

¶1 The State seeks to appeal the ruling of the Will County circuit court that excluded the

admission of evidence obtained pursuant to a valid search warrant at a bench trial. The State argues

that, while brought as an objection on relevancy grounds, the defendant, Christopher D. Dewey,

substantively raised a midtrial motion to suppress evidence, which was improperly granted by the

court. The defendant alleges that the exclusion of evidence was an evidentiary ruling that, pursuant

to Illinois Supreme Court Rule 604(a) (eff. Oct. 19, 2023) and the cases interpreting it, divests this

court of jurisdiction to hear the State’s appeal.

¶2 I. BACKGROUND ¶3 On October 19, 2016, relevant to this appeal, the defendant was charged with eight counts

of unlawful sale of drug paraphernalia (720 ILCS 600/3(a) (West 2016)), two counts of money

laundering (720 ILCS 5/29B-1(a)(1) (West 2016)), and one count of fictitious or unlawfully altered

identification card (15 ILCS 335/14A(b)(1) (West 2016)) based on conduct occurring between

June 15 and September 30, 2016. That same day, Agent Anthony Anderson, a member of the

Illinois State Police Narcotics and Currency Interdiction Task Force, submitted a sworn complaint

for a search warrant with the court seeking access to a Kendall County residence that was affiliated

with the defendant. On November 2, 2016, Anderson submitted a second complaint for a search

warrant seeking access to a UPS store, which contained shipping items that the State believed

would connect the defendant to an illicit online enterprise.

¶4 On March 2, 2018, the defendant moved to suppress any evidence procured during the

execution of the search warrants, attacking the propriety of the issuance of the warrants. The

motion to suppress was denied. In June 2022, pursuant to the defendant’s motion in limine, the

court barred expert witness testimony due to untimely disclosure. The State filed an interlocutory

appeal on July 13, 2022. This court reversed the circuit court’s judgment and remanded for further

proceedings. People v. Dewey, 2023 IL App (3d) 220285-U, ¶ 36.

¶5 Following remand, the case proceeded to a bench trial on October 30, 2023. The State’s

first witness was Anderson. On his third day of testimony, Anderson began to answer questions

regarding the execution of the October 19, 2016, search warrant. Defense counsel raised a

relevancy objection to the testimony, arguing that the defendant was not charged with any conduct

from October 2016 and anything arising from that warrant would be a Kendall County matter. The

defendant was charged with conduct alleged to have occurred in June, July, and September 2016.

The prosecutor responded that the case was like “long-term narcotics investigations, when [they]

2 do a number of street buys, and then months or long periods of time later would execute a search

warrant on a residence,” which could yield evidence that was relevant to earlier conduct such as

business, phone, and computer records related to ongoing purchases.

¶6 In response, defense counsel stated:

“Judge, I don’t think you can go a long time, because, otherwise, there’s not a basis

for a search warrant. So I’m not sure where he’s going with that.

But there is nothing—we’ve already gone through all these transactions, all

the records they have, and—pertaining to it, and the actual transactions themself,

and the substances involved. There’s nothing else that would come, you know,

months later that would be indicative of something that happened in June, July, and

September. This is just an attempt to try to dirty up [the defendant] with things that

are not relevant material to these particular charges.”

The prosecutor declared that arguments advanced by defense counsel should have been argued in

a motion to suppress. The prosecutor further explained to the court that the evidence recovered

from the residence “[would] show that he was operating a business out of that residence.”

Additionally, the evidence, which included the types of items located in the residence, records of

the purchase of large quantities of those items, and the ongoing sale of those items, was necessary

circumstantial evidence of the defendant’s state of mind.

¶7 After a short recess, the court sustained the objection, stating:

“The Court sees in this instance the issue of a search warrant that was

executed three weeks after the date of the last charged offense in this case. And the

Court believes that it is tantamount to subsequent bad acts, other bad acts, which

is—would be no different than prior or other bad acts in this case that would not be

3 admissible for the purpose of establishing propensity. Which, it seems to me that

the testimony that would come out of that search warrant, based on the arguments

of counsel, is likely to touch upon inadmissible propensity evidence and would be

more prejudicial than probative. And so I’m going to sustain the objection.”

On November 2, 2023, the State filed a notice of appeal and certificate of substantial impairment.

Defense counsel argued that the State could not appeal the court’s ruling, as it was not a

suppression order but an evidentiary ruling on an evidentiary objection made by the defendant.

The State was allowed to file the appeal.

¶8 II. ANALYSIS

¶9 On appeal, the State argues that the court erred in entertaining the defendant’s midtrial

objection that sought to suppress legally obtained, relevant, material evidence. At the outset, we

have a duty to consider our jurisdiction and to dismiss the appeal if jurisdiction is lacking. People

v. Garcia, 2015 IL App (1st) 131180, ¶ 65. In criminal trials, the State has a limited right to appeal

from interlocutory orders that have the substantive effect of, inter alia, suppressing evidence. Ill.

S. Ct. R. 604(a)(1) (eff. Oct. 19, 2023). Pretrial orders suppressing evidence are generally

appealable; however, midtrial orders resulting in the suppression of evidence operate under

different rules, “because such orders have a disruptive effect on ongoing trials and burden the

defendant.” People v. Phillips, 2011 IL App (2d) 101142, ¶ 12. A midtrial order “suppressing

evidence,” within the meaning of Rule 604(a)(1),

“is one in which the evidence is suppressed and denied admittance because it was

illegally obtained in violation of a constitutional or statutory right, or even though

lawfully obtained, its admittance is to be denied because of a statutory prohibition

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

Related

People v. Flatt
412 N.E.2d 509 (Illinois Supreme Court, 1980)
People v. Benda
464 N.E.2d 1268 (Appellate Court of Illinois, 1984)
People v. Johnson
447 N.E.2d 502 (Appellate Court of Illinois, 1983)
People v. Phillips
2011 IL App (2d) 101142 (Appellate Court of Illinois, 2011)
People v. Sims
2019 IL App (3d) 170417 (Appellate Court of Illinois, 2019)
People v. Dewey
2023 IL App (3d) 220285-U (Appellate Court of Illinois, 2023)

Cite This Page — Counsel Stack

Bluebook (online)
2025 IL App (3d) 230611, 258 N.E.3d 139, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-dewey-illappct-2025.