People v. Duhaime

2021 IL App (4th) 200557-U
CourtAppellate Court of Illinois
DecidedAugust 10, 2021
Docket4-20-0557
StatusUnpublished

This text of 2021 IL App (4th) 200557-U (People v. Duhaime) 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. Duhaime, 2021 IL App (4th) 200557-U (Ill. Ct. App. 2021).

Opinion

NOTICE FILED This Order was filed under August 10, 2021 Supreme Court Rule 23 and 2021 IL App (4th) 200557-U Carla Bender is not precedent except in the 4th District Appellate limited circumstances al- NO. 4-20-0557 Court, IL lowed under Rule 23(e)(1). IN THE APPELLATE COURT

OF ILLINOIS

FOURTH DISTRICT

THE PEOPLE OF THE STATE OF ILLINOIS, ) Appeal from the Plaintiff-Appellee, ) Circuit Court of v. ) Woodford County JEFFREY D. DUHAIME, ) No. 16CF31 Defendant-Appellant. ) ) Honorable ) Charles M. Feeney III, ) Judge Presiding.

JUSTICE STEIGMANN delivered the judgment of the court. Justices DeArmond and Cavanagh concurred in the judgment.

ORDER

¶ 1 Held: The appellate court affirmed defendant’s 19-year sentence for drug-induced homicide because the trial court (1) was not required to obtain a new presentence investigation report and (2) did not err by finding no statutory factors in mitigation.

¶2 In March 2016, the State indicted defendant, Jeffrey D. Duhaime, on three counts

(counts I-III) of drug-induced homicide (720 ILCS 5/9-3.3(a) (West 2014)) and two counts (counts

IV-V) of delivery of a controlled substance (720 ILCS 570/401(c)(7)(ii), 401(d) (West 2014)). The

State alleged that on December 18, 2015, defendant delivered lysergic acid diethylamide (LSD) to

Keionta Williams, which caused her death. Counts I and IV alleged that defendant delivered more

than 10 objects containing LSD in violation of section 401(c) of the Illinois Controlled Substances

Act (Act) (id. § 401(c)). Under the drug-induced homicide statute, a person who commits a

drug-induced homicide in violation of section 401(c) of the Act is subject to a prison sentence of not less than 15 years and not more than 30 years. 720 ILCS 5/9-3.3(c) (West 2014).

¶3 In December 2016, a jury convicted defendant on all counts. In February 2017, the

trial court sentenced defendant to 20 years in prison under subsection (c) of the drug-induced

homicide statute. See id.

¶4 On appeal, this court affirmed defendant’s convictions for drug-induced homicide

and delivery of a controlled substance but vacated defendant’s convictions for delivering more

than 10 objects containing LSD, concluding the evidence was insufficient. People v. Duhaime,

2019 IL App (4th) 170223-U, ¶¶ 91, 101. We remanded the case for a new sentencing hearing. Id.

¶ 101.

¶5 In February 2020, the trial court conducted a sentencing hearing on defendant’s

remaining convictions and sentenced him to 19 years in prison.

¶6 Defendant appeals, arguing the trial court (1) erred by failing to obtain and consider

an updated presentence investigation report (PSI) and (2) abused its discretion when it failed to

consider a statutory factor in mitigation. We disagree and affirm.

¶7 I. BACKGROUND

¶8 A. The Charges

¶9 In March 2016, the State indicted defendant on three counts of drug-induced

homicide and two counts of delivery of a controlled substance. Count I alleged defendant

(1) committed drug-induced homicide by delivering more than 10 objects containing LSD in

violation of subsection (c) of section 401 of the Act (720 ILCS 570/401(c)(7)(ii) (West 2014)) to

individuals attending a party in Kappa, Illinois, on December 18, 2015, and (2) Keionta Williams

died as a result of ingesting that LSD. Because count I alleged delivery of more than 10 objects,

defendant upon conviction was subject to a sentence of between 15 and 30 years in prison. See

-2- 720 ILCS 5/9-3.3(c) (West 2014). Counts II and III alleged (1) defendant delivered LSD in

violation of subsection 401(d) of the Act and (2) Williams died as a result of ingestion of that LSD.

If convicted of either count II or III, defendant was subject to a sentence as in any other Class X

felony—namely, a prison sentence between 6 to 30 years. See id. § 9-3.3(b).

¶ 10 Count IV alleged defendant delivered more than 10 objects containing LSD to

individuals at the party on December 18, 2015, a Class 1 felony. See 720 ILCS 570/401(c)(7)(ii)

(West 2014). Count V alleged defendant delivered LSD to Williams at that same party, a Class 2

felony. See id. § 401(d).

¶ 11 B. The Trial

¶ 12 In December 2016, the trial court conducted defendant’s jury trial. A more detailed

description of the evidence presented at trial can be found in our prior decision. See Duhaime,

2019 IL App (4th) 170223-U, ¶¶ 13-49.

¶ 13 In summary, the evidence showed that on December 18, 2015, Williams and a

friend attended a party organized in part by defendant in Kappa. At the party, Williams and her

friend obtained LSD from defendant. A few hours after taking the LSD, Williams “freak[ed] out,”

“looked terrified,” and “took off running” into a field adjacent to the party. Partygoers looked for

Williams in the surrounding area but could not locate her. At around 2 a.m., a bus traveling north

on Interstate 39 struck and killed Williams, whom a crash reconstruction expert determined was

walking in a lane of traffic. Several partygoers identified defendant as the person who sold

Williams and others LSD.

¶ 14 The jury convicted defendant on all five counts, including delivery of more than 10

objects of LSD.

¶ 15 C. The Sentencing Hearing

-3- ¶ 16 In February 2017, the trial court conducted defendant’s sentencing hearing. The

court noted that counts II through V were lesser included offenses of drug-induced homicide and

therefore sentenced defendant only on count I, which had a sentencing range of 15 to 30 years in

prison. The presentence investigation report indicated defendant had (1) prior convictions

involving drugs and (2) completed drug treatment. The court believed defendant’s prior

involvement with drugs, as well as his continued involvement after treatment, demonstrated that

(1) he should have known the dangers of drug dealing and (2) a lengthy sentence was necessary to

deter others. The court also noted that defendant blamed others for his problems rather than taking

responsibility and his attitude—demonstrated by his actions and demeanor both before his arrest

and during the criminal proceedings—showed “arrogance” and lack of rehabilitative potential. The

court sentenced defendant to 20 years in prison to be served at 75%.

¶ 17 D. The Direct Appeal

¶ 18 On direct appeal, defendant challenged his convictions on the grounds that (1) the

trial court gave an improper jury instruction for causation and (2) the State failed to present

sufficient evidence to support a conviction beyond a reasonable doubt. This court concluded that

(1) the jury was properly instructed, (2) the State presented sufficient evidence that defendant’s

delivery of LSD to Williams was a cause of her death, and (3) the evidence that defendant delivered

more than 10 objects containing LSD was so unsatisfactory that it created a reasonable doubt as to

defendant’s guilt. Duhaime, 2019 IL App (4th) 170223-U.

¶ 19 This court vacated defendant’s convictions on counts I and IV. Because the trial

court sentenced defendant only on count I, we remanded the case for a new sentencing hearing. Id.

¶ 103.

¶ 20 E. The Proceedings on Remand

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Bluebook (online)
2021 IL App (4th) 200557-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-duhaime-illappct-2021.