People v. Dye

2026 IL App (4th) 241001
CourtAppellate Court of Illinois
DecidedFebruary 2, 2026
Docket4-24-1001
StatusPublished

This text of 2026 IL App (4th) 241001 (People v. Dye) 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. Dye, 2026 IL App (4th) 241001 (Ill. Ct. App. 2026).

Opinion

2026 IL App (4th) 241001 FILED February 2, 2026 NO. 4-24-1001 Carla Bender 4th District Appellate IN THE APPELLATE COURT Court, IL

OF ILLINOIS

FOURTH DISTRICT

THE PEOPLE OF THE STATE OF ILLINOIS, ) Appeal from the Plaintiff-Appellee, ) Circuit Court of v. ) McDonough County JOSHUA T. DYE, ) No. 23CF56 Defendant-Appellant. ) ) Honorable ) Nigel D. Graham ) Judge Presiding.

JUSTICE DOHERTY delivered the judgment of the court, with opinion. Presiding Justice Steigmann and Justice Knecht concurred in the judgment and opinion.

OPINION

¶1 Defendant Joshua T. Dye appeals from his conviction on three counts of predatory

criminal sexual assault of a child (720 ILCS 5/11-1.40(a)(1) (West 2022)), arguing that (1) there

was insufficient evidence presented by the State on each count to prove him guilty beyond a

reasonable doubt and (2) the trial court erred when it failed to comply with Illinois Supreme Court

Rule 431 (eff. July 1, 2012) when admonishing the jury.

¶2 For the reasons set forth below, we affirm in part, reverse in part, and remand for

further proceedings.

¶3 I. BACKGROUND

¶4 A. Charges Against Defendant

¶5 On May 18, 2023, defendant was charged by information with three counts of predatory criminal sexual assault of a child (720 ILCS 5/11-1.40(a)(1) (West 2022)) for actions

that allegedly occurred between November 1, 2022, and May 15, 2023, involving I.B., a child

under the age of 13 years. Count I alleged that defendant “caused his finger to make contact with

I.B.’s vagina for the purpose of [his] sexual gratification.” Count II alleged that defendant “caused

his finger to make contact with I.B.’s anus for the purpose of [his] sexual gratification” (see id.),

and count III made the same allegation concerning defendant’s mouth and I.B.’s vagina (see id.).

At the time, I.B. was four years old. Each charge involved a Class X felony that carried with it a

mandatory term of imprisonment of between 6 and 60 years, with a mandatory supervised release

period of between 3 years and natural life. Id. § 11-1.40(b).

¶6 B. Trial

¶7 The case went to trial in April 2024. Prior to the empaneling of the jury, the trial

court addressed the admissibility of I.B.’s pretrial out-of-court statements.

¶8 1. Section 115-10 Hearing

¶9 Prior to trial, the State filed its notice of intent to use hearsay statements made by

I.B. to her mother, Elizabeth B., before and after I.B.’s Children’s Advocacy Center (CAC)

interview and to the CAC interviewer. See 725 ILCS 5/115-10 (West 2024). The trial court ruled

that both statements were admissible. The court found that the CAC “interview was conducted in

an objective fashion” and that none of the questioning “was overly suggestive.” The court stated

that the questions to I.B. were not leading and that “[t]here were follow-up questions related to

what the minor stated. [The] line of questioning was, essentially, led by the answers that were

given.” The court took into account the fact that I.B. would be testifying at trial and found that

“the terminology [was] consistent with a child this child’s age.” As a result, the court concluded

there were “sufficient safeguards of reliability with respect to [the CAC] statements.”

-2- ¶ 10 Concerning the statements purportedly made to I.B.’s mother, the trial court found

they were sufficiently reliable and concluded that any suggestions made to I.B. by the mother

during the questioning came in response to questions from I.B. and for clarification. The court

further found that the “statements go to the reasons that [Elizabeth] took the minor to the hospital

and the [CAC] interview which further makes them relevant and explaining [of] her actions.” As

to the statement I.B. purportedly made on the day following her CAC interview, the court found it

consistent with her interview and further found it spontaneous, which “gave it sufficient safeguards

of reliability.”

¶ 11 2. Voir Dire

¶ 12 Jury selection moved forward in groups, with the trial court asking the initial

questions of each prospective panel. In all, there were four groups of potential jurors. For all panels

except the third, the judge asked a set of questions based on Illinois Supreme Court Rule 431(b)

(eff. July 1, 2012) concerning “certain fundamental principles of American law.” In accordance

with Rule 431(b), the court asked three of the potential juror groups (groups one, two, and four) if

they understood and accepted that (1) defendant is presumed to be innocent of the charges against

him, (2) the State must prove defendant is guilty beyond a reasonable doubt before he can be

convicted, (3) defendant is not required to offer any evidence on his behalf, and (4) defendant’s

silence cannot be held against him. Id. Each potential juror in these three groups was asked to

acknowledge and accept these principles, commonly known as the Zehr principles (see People v.

Zehr, 103 Ill. 2d 472 (1984)), and each did so on the record.

¶ 13 However, as to potential juror group three, the trial court did not specifically read

Rule 431(b) or ask potential jurors whether they understood and accepted each of its admonitions.

The court individually questioned prospective juror Dunlap—the only potential juror from group

-3- three ultimately empaneled in the case—as follows:

“THE COURT: Okay. Do you know of any reason why you cannot be a fair

and impartial juror in this case?

PROSPECTIVE JUROR DUNLAP: No.

THE COURT: Is there anything about the nature of the charge in this case

that would prevent you from rendering a fair and impartial decision?

THE COURT: Will you apply the law as the Court states it to be without

regard to your own personal feelings about what the law should be?

PROSPECTIVE JUROR DUNLAP: Yes.

THE COURT: And if you were chosen to be on this jury, if you believe that

the State had failed to prove the Defendant guilty beyond a reasonable doubt, would

you have any hesitation in returning a verdict of not guilty?

PROSPECTIVE JUROR DUNLAP: No hesitation.

THE COURT: If you believe the State had proven the Defendant guilty

beyond a reasonable doubt, would you have any hesitation in returning a verdict of

guilty?

THE COURT: Is there anything that’s come to mind that’s raised any doubt

in your own mind as to whether you can serve as a juror?

PROSPECTIVE JUROR DUNLAP: No.”

¶ 14 On further questioning, prospective juror Dunlap added:

“PROSPECTIVE JUROR DUNLAP: Well, I gave a deposition for a case

-4- October, November of last year and it was—I was part of a tutoring program in

college. And one of the tutors had been accused of sexual misconduct with one of

my students.

THE COURT: Is there anything about that experience that would cause you

to feel either sympathy or prejudice for someone accused of a crime?

¶ 15 The record indicates that the third panel of prospective jurors was present in the

courtroom during the questioning of the first two panels. No objection was raised regarding the

trial court’s failure to discuss Rule 431(b) with juror Dunlap.

¶ 16 3. The Trial Witnesses and CAC Statement

¶ 17 a. Elizabeth B.

¶ 18 Elizabeth B. testified that I.B. was born in 2018. Elizabeth had been married since

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Bluebook (online)
2026 IL App (4th) 241001, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-dye-illappct-2026.