People v. Franklin

2020 IL App (4th) 180527-U
Procedural entryThis page is a short order in People v. Franklin. Read the opinion of the Court — 2020 IL App (1st) 171628
Appellate Court of Illinois·Decided November 16, 2020·No. 4-18-0527·Unpublished

Opinion

NOTICE 2020 IL App (4th) 180527-U This order was filed under Supreme FILED NO. 4-18-0527 November 16, 2020 Court Rule 23 and may not be cited as precedent by any party except in Carla Bender the limited circumstances allowed IN THE APPELLATE COURT 4th District Appellate under Rule 23(e)(1). Court, IL OF ILLINOIS

FOURTH DISTRICT

THE PEOPLE OF THE STATE OF ILLINOIS, ) Appeal from Plaintiff-Appellee, ) Circuit Court of v. ) Champaign County RIO M. FRANKLIN, ) No. 17CF511 Defendant-Appellant. ) ) Honorable ) Heidi N. Ladd, ) Judge Presiding.

JUSTICE HOLDER WHITE delivered the judgment of the court. Presiding Justice Steigmann and Justice Cavanagh concurred in the judgment.

ORDER ¶1 Held: The appellate court affirmed, concluding the trial court (1) did not abuse its discretion in admitting lay witness identification testimony, (2) did not err in considering defendant’s demeanor as a factor in sentencing defendant to 25 years’ imprisonment, and (3) conducted an adequate Krankel inquiry into defendant’s posttrial ineffective assistance of counsel claim.

¶2 Following a May 2018 trial, a jury found defendant, Rio M. Franklin,

guilty of aggravated robbery (720 ILCS 5/18-1(b)(1) (West 2016)). In June 2018, the

trial court sentenced defendant to 25 years’ imprisonment.

¶3 Defendant appeals, arguing (1) the trial court erred by requiring jurors to

watch the surveillance video in the courtroom and for instructing them that they were not

to deliberate while the video was being played, (2) the trial court erred by allowing

Ramsey Rusef to identify defendant from still photographs taken from the surveillance video, (3) defendant’s case should be remanded for a new sentencing hearing where the

court considered his demeanor during trial as an aggravating factor at sentencing, and

(4) defendant’s case should be remanded for an adequate Krankel inquiry. We affirm.

¶4 I. BACKGROUND

¶5 In April 2017, the State charged defendant with aggravated robbery (720

ILCS 5/18-1(b)(1) (West 2016)), alleging “defendant took property from Rebecca

Stuckey by threatening the imminent use of force while indicating physically that he was

armed with a firearm[.]” The charge stemmed from a February 25, 2017, robbery at a

Circle K gas station in Urbana, Illinois.

¶6 A. Pretrial Proceedings

¶7 In May 2018, the State filed a motion in limine pursuant to People v.

Thompson, 2016 IL 118667, 49 N.E.3d 393, asking the trial court to hold a hearing

outside the presence of the jury to address the issue of admissibility of lay opinion

identification testimony of Illinois Department of Corrections (DOC) Parole Agent

Ramsey Rusef. The State sought to introduce Rusef’s testimony as to his identification

of defendant from an image taken from a Circle K gas station surveillance video.

¶8 According to the State’s motion, a robbery occurred at a Circle K gas

station on February 25, 2017. Video surveillance captured a black male “enter the Circle

K gas station and proceed to rob clerk Rebecca Stuckey, during which the offender points

what appears to be a gun at Stuckey, secures her hands behind her back with zip[]ties,

and attempts to gain access to cash registers and a safe.” “Pursuant to the investigation of

the robbery, on April 13, 2017, [DOC] Parole Agent Ramsey Rusef viewed still

photographs taken from the Circle K surveillance video depicting the robbery. In

-2- reviewing said still images, Agent Rusef recognized and identified Defendant Rio

Franklin as the offender in the video.” Rusef previously met with defendant on March 8,

2017, in his capacity as defendant’s parole officer.

¶9 Subsequent to the filing of the motion in limine, the trial court held a

hearing on the motion. At the hearing, Rusef testified he met with defendant, in his

official capacity as a parole agent, on March 8, 2017, for 45 minutes, at defendant’s

girlfriend’s residence. On April 13, 2017, the Urbana Police Department contacted Rusef

and asked him to view photographs on the Champaign County Facebook page to attempt

to identify defendant as the suspect in the February 2017 aggravated robbery.

¶ 10 The State asked Rusef if he recognized the person in the photographs on

the Facebook page. Rusef responded, “I actually consulted—I had to consult with the

DOC web page because I’d only seen [defendant] one time prior.” After Rusef viewed

defendant’s photograph on the DOC website and the still photograph from the

surveillance video on the Facebook page, he stated, “it definitely could be [defendant].”

Rusef explained, “[Defendant] has a very distinctive cheek bone and right around his

eyes is a very distinct high cheek bone that was present in the pictures from the Circle K

as well as the DOC website.”

¶ 11 The trial court heard arguments from both parties and analyzed Rusef’s

lay opinion testimony pursuant to the factors in Thompson and People v. Mister, 2016 IL

App (4th) 130180-B, 58 N.E.3d 1242. In analyzing the factors set out in Thompson, the

court stated, “Both parties have argued the factors set forth in Thompson, and it is a

totality of the circumstances, the absence of any particular factor does not necessarily

render the testimony inadmissible.” The court found Mister “held that a lay witness may

-3- testify regarding the identity of a person depicted in a surveillance video if there is some

basis for concluding that the witness is more likely to correctly identify that individual

than the jury, adopting obviously the directives of Thompson. Also, that the lay witness’s

familiarity with a person then goes to the weight to be given to the witness’s testimony,

not admissibility of such testimony.”

¶ 12 Ultimately, the trial court granted the State’s motion to admit Rusef’s lay

opinion testimony. In support of its ruling, the court stated,

“I find here that in weighing all of [the] factors then

there is sufficient evidence that this should go to the jury

and it is for them to determine what weight, if any, to be

given to them. The certainty of witness identification is

one that both by statute, 725 ILCS 5/115-5, and Illinois

Rule of Evidence [801(d)(1)(B)] is for the trier of fact to

evaluate, including the level of certainty in making the

identification. So that would be something for the trier of

fact, but not bar its admission.

Having weighed all of these factors, I think that a

prophylactic ruling, which the state is conceding is

necessary, would then address any of the concerns about

the prejudicial value, and that is that the state would be

barred from making any reference to the occupation of

Agent Rusef or the fact that he works as a parole officer or

for the [DOC]. He obviously could testify to the time,

-4- place and circumstances of the meeting in the sense of who

was present, how far away, where they stood, conversation

took place, observations he made. Any testimony as to

photographs he reviewed other than the stills made from

the videotape would absolutely have to redact any reference

to booking photographs or records or anything from the

[DOC] and simply be photographs in the witness’s

possession or that he was familiar with, but he cannot make

any reference to where they were stored or how he had

access to those or what type of photographs they were.

Free access — add to your briefcase to read the full text and ask questions with AI

People v. Franklin, 2020 IL App (4th) 180527-U (Ill. Ct. App. 2020).

2020 IL App (4th) 180527-U (People v. Franklin) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

People v. Balls
419 N.E.2d 571 (Appellate Court of Illinois, 1981)
People v. Wilson
885 N.E.2d 1033 (Illinois Supreme Court, 2008)
People v. McCain
617 N.E.2d 1294 (Appellate Court of Illinois, 1993)
The People v. Adkins
242 N.E.2d 258 (Illinois Supreme Court, 1968)
People v. Hillier
931 N.E.2d 1184 (Illinois Supreme Court, 2010)
People v. Moore
797 N.E.2d 631 (Illinois Supreme Court, 2003)
People v. Enoch
522 N.E.2d 1124 (Illinois Supreme Court, 1988)
People v. Krankel
464 N.E.2d 1045 (Illinois Supreme Court, 1984)
People v. Heider
896 N.E.2d 239 (Illinois Supreme Court, 2008)
People v. Fern
723 N.E.2d 207 (Illinois Supreme Court, 1999)
People v. Piatkowski
870 N.E.2d 403 (Illinois Supreme Court, 2007)
People v. Barrow
549 N.E.2d 240 (Illinois Supreme Court, 1989)
People v. Caffey
792 N.E.2d 1163 (Illinois Supreme Court, 2001)
People v. Alexander
940 N.E.2d 1062 (Illinois Supreme Court, 2010)
People v. Snyder
959 N.E.2d 656 (Illinois Supreme Court, 2011)
People v. Jolly
2014 IL 117142 (Illinois Supreme Court, 2014)
People v. Jolly
2014 IL 117142 (Illinois Supreme Court, 2015)
People v. Snyder
2011 IL 111382 (Illinois Supreme Court, 2011)
People v. Thompson
2016 IL 118667 (Illinois Supreme Court, 2016)
People v. Mister
2016 IL App (4th) 130180-B (Appellate Court of Illinois, 2016)