People v. Downs

2024 IL App (1st) 221226-U
CourtAppellate Court of Illinois
DecidedApril 15, 2024
Docket1-22-1226
StatusUnpublished

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Bluebook
People v. Downs, 2024 IL App (1st) 221226-U (Ill. Ct. App. 2024).

Opinion

2024 IL App (1st) 221226-U No. 1-22-1226

FIRST DIVISION April 15, 2024

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 DISTRICT ______________________________________________________________________________

THE PEOPLE OF THE STATE OF ILLINOIS, ) Appeal from the Circuit Court ) of Cook County. Plaintiff-Appellee, ) ) v. ) No. 19 CR 14226 ) RICHARD DOWNS, ) ) The Honorable Defendant-Appellant. ) James B. Linn, ) Judge, presiding. ) ______________________________________________________________________________

JUSTICE PUCINSKI delivered the judgment of the court. Presiding Justice Fitzgerald Smith and Justice Coghlan concurred in the judgment.

ORDER

¶1 Held: (1) The State proved beyond a reasonable doubt that defendant committed first degree murder. (2) The circuit court did not err when it admitted the other-crimes evidence, nor did the admission of other-crimes evidence prejudice defendant. (3) Defendant’s challenge based on the use of an investigative alert is without merit, as the admission of evidence derived from the arrest would be harmless error if the arrest was held unconstitutional.

¶2 Defendant, Richard Downs, appeals his conviction of first degree murder. He argues that

the State failed to establish that he was the individual who committed the murder since only

circumstantial evidence linked him to the crime; the circuit court erred when it admitted other- 1-22-1226

crimes evidence; and his arrest pursuant to an investigative alert violated his Illinois

constitutional right against unreasonable seizures. We affirm.

¶3 BACKGROUND

¶4 A grand jury indicted defendant with two counts of first degree murder (720 ILCS 5/9-

1(a)(1), (a)(2) (West 2016)). The indictment alleged that defendant stabbed and killed Kevin

Faulkner. Defendant entered a plea of not guilty. Prior to proceeding to a jury trial, both parties

filed pretrial motions.

¶5 A. Motion to Quash Arrest and Suppress Evidence

¶6 Defendant filed a motion to quash arrest and suppress evidence wherein he argued that

the police lacked probable cause to arrest him. At the hearing on the motion, Detective Williams

Sullivan testified he received an assignment to investigate a homicide that took place at 8334

South Cottage Grove on November 6, 2016. Sullivan was informed that the Illinois State Police

Crime Lab recently determined that defendant’s DNA was associated with DNA collected from

the crime scene.

¶7 Sullivan reviewed reports, reviewed defendant’s criminal history, reviewed videos, and

reinterviewed witnesses. Sullivan learned that defendant had three prior incidents involving the

use of a knife. A witness captured the incident with her cellphone, and she provided the video to

the police. The attacker in the cellphone video had grey hair. Two witnesses described the

attacker as five feet, five inches tall. Defendant had grey hair and was five feet, five inches tall.

¶8 Sullivan instructed the fugitive apprehension unit to arrest defendant. He did not obtain

an arrest warrant. Two officers surveilled defendant’s home. The officers arrested defendant

when he exited his home on September 12, 2019. The arresting officers recovered a folding

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knife. While defendant was in custody, Sullivan obtained a search warrant for a buccal swab

from defendant.

¶9 Following argument, the circuit court denied the motion.

¶ 10 B. Motion to Admit Other-Crimes Evidence

¶ 11 The State filed a motion to allow proof of other-crimes evidence. The State proffered

three prior incidents. In 2006, defendant engaged in a verbal altercation with Richard Jones.

During the altercation, defendant first threw a bottle at Jones, and then he grabbed him by his

shirt and stabbed him multiple times with a pocketknife. In 2013, defendant walked up to

Christopher Warner and stabbed him with a pocketknife near the 8600 block of South Ingleside.

Defendant was upset about something. In 2014, defendant was in a relationship with Willie Mae

Allen. During a verbal altercation with Allen, Defendant pulled out a knife. He then stuck his

thumb in her eye. A third individual broke down the bedroom door and removed defendant off

Allen. The State sought to introduce the other-crimes evidence based on modus operandi,

identity, and intent.

¶ 12 The circuit court granted the State’s motion with respect to the 2013 and 2014 incident.

The circuit court reasoned that defendant had a consistent pattern of sudden unprovoked fits of

violence with a knife. While the circuit court considered the 2006 incident in its analysis, it

determined that the incident was too remote.

¶ 13 C. Trial

¶ 14 At trial, Rosezita Whitehead testified that she lived at 8334 South Cottage Grove Avenue,

Chicago, Illinois on November 6, 2016. At approximately 11:20 p.m., she heard a commotion

outside the front of her building. From her window, she saw one man grab another man off his

bicycle. Whitehead ran to grab her phone. When she returned, the two men where on the ground.

-3- 1-22-1226

Whitehead described both men as black and older. She estimated that the man on top was

approximately five feet, six inches to five feet, nine inches tall. During the entire encounter, the

man on the bike was always on the bottom. The two men did not roll around, or change

positions. Whitehead believed that the man on top leaned over and took something from the

other man. The man on top walked away. The other man stayed on the ground, and he called out

for help. Whitehead stopped recording, and she called the police.

¶ 15 The court admitted People’s Exhibit 3 into evidence. Whitehead identified People's

Exhibit 3 as the video she recorded with her cellphone on November 6, 2016, at approximately

11:20 p.m. In the video, a man with short grey hair wrestles with another man wearing a red

jacket. The grey-haired man always remains on top. Throughout the video, the grey-haired man

grabs the other man at the back right shoulder of his red jacket. At one point, the grey-haired

man presses his head at the same position on the jacket.

¶ 16 On cross-examination, Whitehead admitted that she could not see either man’s face. She

initially thought that the man on top wore a hat, but she later believed that he had “greyish” hair.

On redirect examination, Whitehead clarified that the man on the bicycle also wore a jacket. The

grey-haired man grabbed the victim at the top portion of his jacket.

¶ 17 Darrain Bowdry testified that he lived at 8334 South Cottage Grove Avenue, Chicago,

Illinois on November 6, 2016. At approximately 11:20 p.m., he heard a commotion outside the

front of his building. By the time he looked outside, he saw one man walk away, and another

man moaning on the ground. Both men were black and approximately in their 40s. He did not

see the face of the man that walked away.

¶ 18 Detective Adrian Flores testified that on November 6, 2016, at around 11:20 p.m., he

received a dispatch call for a battery in progress at 8334 South Cottage Grove Avenue. When he

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arrived, other emergency personnel were already at the crime scene. The victim had been

pronounced dead.

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Bluebook (online)
2024 IL App (1st) 221226-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-downs-illappct-2024.