People v. Foster

2026 IL App (5th) 230726-U
CourtAppellate Court of Illinois
DecidedFebruary 2, 2026
Docket5-23-0726
StatusUnpublished

This text of 2026 IL App (5th) 230726-U (People v. Foster) 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. Foster, 2026 IL App (5th) 230726-U (Ill. Ct. App. 2026).

Opinion

NOTICE 2026 IL App (5th) 230726-U NOTICE Decision filed 02/02/26. The This order was filed under text of this decision may be NO. 5-23-0726 Supreme Court Rule 23 and is changed or corrected prior to the filing of a Petition for not precedent except in the

Rehearing or the disposition of IN THE limited circumstances allowed the same. under Rule 23(e)(1). APPELLATE COURT OF ILLINOIS

FIFTH DISTRICT ______________________________________________________________________________

THE PEOPLE OF THE STATE OF ILLINOIS, ) Appeal from the ) Circuit Court of Plaintiff-Appellee, ) Madison County. ) v. ) No. 21-CF-2921 ) STEVEN FOSTER, ) Honorable ) Neil T. Schroeder, Defendant-Appellant. ) Judge, presiding. ______________________________________________________________________________

PRESIDING JUSTICE CATES delivered the judgment of the court. Justices Moore ∗ and Boie ** concurred in the judgment.

ORDER

¶1 Held: The defendant was deprived of a fair trial where he established that the admission of the phone records, including the geolocation data, and the video interview, along with the improper testimony by law enforcement regarding the defendant’s credibility constituted plain error. The judgment of conviction is reversed, and the cause is remanded for a new trial.

¶2 A jury found the pro se defendant, Steven Foster, guilty of multiple counts, including three

counts of attempt murder. He was sentenced to a total of 135 years in the Illinois Department of

Corrections (IDOC). On direct appeal, the defendant claims that cumulative error denied the

defendant of a fair trial; the circuit court failed to provide proper admonishments for waiver of

∗ Justice Moore fully participated in the decision prior to his retirement. See Cirro Wrecking Co. v. Roppolo, 153 Ill. 2d 6 (1992). ** For administrative reasons Justice Boie has been substituted on the panel. Justice Boie has read the briefs in this case and has listened to the recording of oral argument. 1 counsel under Illinois Supreme Court Rule 401(a); the State failed to provide notice before raising

a transferred intent argument during its rebuttal in closing arguments; the State engaged in

pervasive prosecutorial misconduct during voir dire and closing arguments; and the 135-year

sentence was excessive given the nature of the case and the defendant’s rehabilitative potential.

For the following reasons, we reverse and remand for a new trial.

¶3 I. BACKGROUND

¶4 On September 8, 2021, a shooting occurred at Oakwood Estates, a housing complex in

Alton, Illinois, where a group of individuals were socializing outside that evening. Among this

group was Kenneth (Ken) Jones, who was intoxicated. Ken began antagonizing two other people,

namely Darylann Hardimon and Danyelle Gaston. The confrontation escalated and Darylann

contacted her boyfriend, the defendant, who arrived shortly thereafter. The defendant argued with

Ken and his friend, Charles Thompson. Law enforcement responded to the commotion and broke

up the gathering. The defendant left, but others gathered again after law enforcement officers were

no longer present. Then, gunshots were fired into the gathering of approximately 20 people. Three

people, Charles Thompson, Jackie Sharp, and Troy Jones, were shot and hospitalized after

sustaining serious injuries from gunshot wounds.

¶5 The defendant was charged on September 16, 2021, by information, with three counts of

attempt first degree murder (720 ILCS 5/8-4(a) (West 2020)); three counts of aggravated battery

with a firearm (720 ILCS 5/12-3.05(e)(1) (West 2020)); one count of armed habitual criminal (720

ILCS 5/24-1.7(a) (West 2020)); one count of aggravated discharge of a firearm (720 ILCS 5/24-

1.2(a)(2) (West 2020)); and one count of unlawful possession of weapons by a felon (720 ILCS

5/24-1.1(a) (West 2020)). An indictment was returned on October 21, 2021, charging the same

conduct and counsel was appointed for the defendant.

2 ¶6 Pretrial

¶7 On September 12, 2022, the defendant filed a motion to proceed pro se, and the circuit

court held a hearing on the defendant’s motion on September 29, 2022. The defendant claimed

that he did not understand the charges. Defense counsel stated that she had gone through the file,

made extensive notes, and discussed the case with the defendant. The circuit court determined that

the defendant was 36 years old, attended a military high school, and had earned some college

credits. The defendant was able to read, write, and understand the English language. He was not

under the influence of drugs or alcohol, and he did not have a physical or mental disability. The

defendant had been involved in prior criminal cases but had never represented himself.

¶8 The circuit court read each count of the information to the defendant and specifically

explained that attempt first degree murder had a sentencing range of 6 to 30 years, and that the

defendant was subject to a firearm enhancement of 25 years to life for each of those charges.

Because the charges involved three different victims, the defendant would be sentenced to

consecutive sentences if convicted on more than one count. The circuit court emphasized that the

defendant faced spending the remainder of his life in prison if found guilty. The additional charges

and their sentencing ranges were also explained to the defendant. The defendant indicated that he

understood each of the charges as explained by the circuit court.

¶9 The circuit court further explained to the defendant that he would be required to adhere to

the rules of evidence at trial and the attorneys that were appointed to represent him had substantial

training and experience in trial procedure. The circuit court cautioned the defendant that the State

was represented by experienced attorneys, and the defendant would be at a disadvantage

representing himself without any trial experience. The defendant was warned that he may be

disadvantaged by failing to object to inadmissible evidence and his tactical decisions may have

3 unintended consequences due to his inexperience. The circuit court additionally cautioned the

defendant that the jury would be able to observe his interactions with the circuit court and

witnesses, and that the defendant’s conduct, attitude, and temperament could affect the judgment

of the trier of fact.

¶ 10 The circuit court found that the defendant understood the nature of the charges and the

possible penalties. The defendant was informed of his right to counsel, and if he were unable to

afford an attorney, one would be appointed for him. The circuit court found that the defendant

understood his right to counsel, and that the defendant made a voluntary, knowing, and intelligent

waiver of his right to counsel. As the defendant’s request for waiver of counsel was accepted by

the circuit court, his public defender was discharged.

¶ 11 On February 8, 2023, the defendant requested the appointment of counsel. The circuit court

granted his request and appointed a public defender. Before defense counsel met with the

defendant, the grand jury returned an amended indictment on February 9, 2023, on the same

charges. The only modification made was on the unlawful possession of weapons by a felon count

which corrected the date of a prior conviction.

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Bluebook (online)
2026 IL App (5th) 230726-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-foster-illappct-2026.