People v. Donaldson

2020 IL App (4th) 180259-U
CourtAppellate Court of Illinois
DecidedSeptember 22, 2020
Docket4-18-0259
StatusUnpublished

This text of 2020 IL App (4th) 180259-U (People v. Donaldson) 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. Donaldson, 2020 IL App (4th) 180259-U (Ill. Ct. App. 2020).

Opinion

NOTICE FILED This order was filed under Supreme 2020 IL App (4th) 180259-U September 22, 2020 Court Rule 23 and may not be cited Carla Bender as precedent by any party except in the limited circumstances allowed NO. 4-18-0259 4th District Appellate under Rule 23(e)(1). Court, IL IN THE APPELLATE COURT

OF ILLINOIS

FOURTH DISTRICT

THE PEOPLE OF THE STATE OF ILLINOIS, ) Appeal from the Plaintiff-Appellee, ) Circuit Court of v. ) Livingston County JAYLAND DONALDSON, ) No. 17CF261 Defendant-Appellant. ) ) Honorable ) Jennifer H. Bauknecht, ) Judge Presiding. ______________________________________________________________________________

JUSTICE HARRIS delivered the judgment of the court. Justices Turner and Cavanagh concurred in the judgment.

ORDER

¶1 Held: (1) The trial court did not err by sentencing defendant to an aggregate 12-year term of imprisonment.

(2) Defendant forfeited his posttrial pro se claims of ineffective assistance of counsel by failing to bring them to the trial court’s attention.

¶2 Following a bench trial, the trial court found defendant, Jayland Donaldson, guilty

of three counts of unlawful delivery of a controlled substance (720 ILCS 570/401(c)(2), (d)(i)

(West 2016); id. § 407(b)(1), (2)) and two counts of unlawful possession with intent to deliver a

controlled substance (id. § 401(c)(2), id. § 407(b)(1); 720 ILCS 550/5(c) (West 2016)) and

sentenced him to an aggregate term of 12 years in prison. Defendant appeals, arguing the court

erred by (1) considering improper aggravating factors at sentencing and imposing an excessive

sentence and (2) failing to inquire into his posttrial pro se claims of ineffective assistance of counsel. We affirm.

¶3 I. BACKGROUND

¶4 In August 2017, the State charged defendant with multiple drug-related offenses,

including three counts of unlawful delivery of a controlled substance (720 ILCS 570/401(c)(2),

(d)(i) (West 2016); id. § 407(b)(1), (2)) (counts I, II, and III); two counts of unlawful possession

of a controlled substance with intent to deliver ((id. § 401(c)(2), id. § 407(b)(1); 720 ILCS 550/5(c)

(West 2016)) (counts IV and VI); and one count of unlawful possession of a controlled substance

(720 ILCS 570/402(c) (West 2016)) (count V). The charges were based on allegations that, on

three occasions in August 2017, defendant sold cocaine to a confidential source during controlled

drug buys that occurred within 1000 feet of public housing; possessed with the intent to deliver

more than a gram of cocaine within 1000 feet of public housing; possessed with the intent to deliver

more than 10 grams but less than 30 grams of a substance containing cannabis; and unlawfully

possessed a substance containing hydrocodone.

¶5 In December 2017 and January 2018, defendant’s bench trial was conducted. The

State’s evidence showed that in August 2017, William Spandet agreed to work as a confidential

source for the police, specifically Sergeant Jeff Hamilton with the Livingston County Proactive

Unit. On August 8, 19, and 22, 2017, Spandet purchased cocaine from defendant during three

controlled drug buys. An unspecified amount of cocaine was sold during the first buy and 2.1

grams and 1.9 grams of cocaine were sold during the second and third buys, respectively. Each

buy occurred in Spandet’s vehicle while it was parked within an approximate 50-foot range of

Meadowview Court, a public housing complex where defendant resided. Regarding how the

location of the controlled buys was chosen, Hamilton testified as follows:

“The first buy the confidential source was directed to meet out there in front

-2- of the parking lot. The second and third buy I believe [defendant] himself directed

the confidential source to park in the same general area. I think on the third time

specifically [defendant] told the confidential source to park a little bit further down

the street out of the way of the cameras of the housing complex.”

¶6 Spandet testified he was told to call Hamilton when he learned of the potential to

buy drugs in Livingston County. He identified defendant as the person who sold him drugs on

three occasions in August 2017. At the time of the first transaction, Spandet knew he had the

potential to buy drugs from either an individual named Chad Callahan or defendant.

¶7 The record shows the State presented audio recordings of the first two drug buys,

which were obtained using a recording device given to Spandet. It also presented surveillance

videos captured by the police of the second and third controlled buys. The audio recording of the

first buy indicates Spandet spoke with an individual other than defendant before ultimately meeting

with defendant and purchasing cocaine. At the conclusion of the controlled buy, Spandet asked if

he could do business with defendant again and defendant replied “anytime.” Upon request,

defendant provided his phone number to Spandet and identified himself as “Jay.” Defendant also

stated as follows: “If you keep f*** with me, a g[ram] is gonna be 80 bucks for you, bro.” After

defendant exited the vehicle, Spandet used a racial slur to describe defendant’s appearance.

¶8 Spandet testified that prior to the second controlled buy, defendant stated he would

sell Spandet an “eight-ball” but then later expressed that he did not have enough cocaine for an

“eight-ball.” As a result, Spandet brought a scale to his meeting with defendant, which was used

during the drug transaction. An audio recording of the second buy reflects defendant expressed

that he wanted a similar scale for himself.

¶9 The same date as the third and final controlled buy, the police executed a search

-3- warrant on defendant’s apartment at the Meadowview Court complex. During the search, the

police located 12.4 grams of cannabis in a cabinet under the kitchen sink; 3.1 grams of “bagged

up” cocaine in a backpack in the living room; 1.2 grams of cocaine inside a “fake tomato paste

container”; a digital scale; empty “baggies”; and currency used during the August 22 controlled

buy.

¶ 10 The State’s evidence further showed that Hamilton interviewed defendant after the

execution of the search warrant. A recording of the interview was admitted into evidence and

played for the trial court. During the interview, defendant acknowledged that the police would find

cannabis, cocaine, a scale, and sandwich bags in his residence. He also admitted that the cocaine

found in the fake tomato paste container belonged to him and that the phone number contacted

during the controlled buys was his number. However, defendant asserted the backpack found in

his residence belonged to an individual named Heather Osmolski, who was at the residence when

it was searched. Hamilton testified that in addition to cocaine, the backpack also contained a digital

scale.

¶ 11 During the recorded interview with Hamilton, defendant further asserted that he

“just started” selling cocaine and was not selling “that much.” When Hamilton asked if defendant

was selling “a couple of grams a day,” defendant agreed, stating he sold cocaine “to make a little

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Bluebook (online)
2020 IL App (4th) 180259-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-donaldson-illappct-2020.