People v. Garduza

2024 IL App (1st) 230431-U
CourtAppellate Court of Illinois
DecidedAugust 16, 2024
Docket1-23-0431
StatusUnpublished

This text of 2024 IL App (1st) 230431-U (People v. Garduza) 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. Garduza, 2024 IL App (1st) 230431-U (Ill. Ct. App. 2024).

Opinion

2024 IL App (1st) 230431-U No. 1-23-0431 Order filed August 16, 2024 Sixth Division

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 Plaintiff-Appellee, ) Cook County. ) v. ) No. 19 CR 1296 01 ) ANDRES GARDUZA, ) Honorable ) Timothy J. Joyce, Defendant-Appellant. ) Judge, presiding.

JUSTICE HYMAN delivered the judgment of the court. Presiding Justice Johnson and Justice C.A. Walker concurred in the judgment.

ORDER

¶1 Held: Reversing defendant’s conviction for unlawful possession of a weapon by a street gang member where the State failed to prove that defendant was a street gang member and remanding for the imposition of sentence on merged counts.

¶2 A jury convicted Andres Garduza of unlawful possession of a firearm by a street gang

member and two counts of aggravated unlawful use of a weapon (AUUW). The trial court merged

the counts and sentenced Garduza to 4½ years’ in prison for unlawful possession of a firearm by

a street gang member. On appeal, he argues the State failed to prove that he was an active member No. 1-23-0431

of a street gang. He also argues ineffective assistance of counsel for failing to request a jury

instruction regarding police officers’ failure to activate their body-worn cameras and admitting to

contested elements of the offenses.

¶3 We reverse Garduza’s conviction and remand for the trial court to impose sentence on the

merged AUUW counts. Our supreme court has interpreted the relevant section as applying to gang

members who actively participate in criminal activities on behalf of the gang. People v. Villareal,

2023 IL 127318. The State failed to prove that Garduza was an active member of a gang.

¶4 Background

¶5 Garduza was charged by indictment with multiple counts alleging he illegally possessed a

firearm. The State proceeded on (i) count I for unlawful possession of a firearm by a street gang

member (720 ILCS 5/24-1.8(a)(1) (West 2018)), (ii) count II for AUUW predicated on lacking a

valid concealed carry license (CCL) and firearm owner’s identification (FOID) card (720 ILCS

5/24-1.6(a)(1), (a)(3)(A-5); (a)(1), (a)(3)(C) (West 2018)), and (iii) count V for AUUW predicated

on being previously adjudicated a delinquent minor for an act that would have been a felony if

committed by an adult (720 ILCS 5/24-1.6(a)(1), (a)(3)(D) (West 2018)).

¶6 At trial, Chicago police officer Jaime Acosta testified that he was a “district intelligence

officer” who obtained intelligence on gang members to disseminate and prevent gang violence. He

had formerly been on a tactical team concentrated “mainly” on “gang-driven shootings.”

¶7 At 11 p.m. on New Year’s Eve 2018, Acosta and Officer Adam Bourdosis entered a

gangway and surveyed the block. Acosta wore a body camera but did not activate it as he did not

want his position discovered. Once activated, the camera beeps loudly every 30 seconds and emits

a bright green light.

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¶8 From the gangway, Acosta saw two people on the sidewalk in front of a residence, several

houses away. One of them, Garduza, removed “a very large firearm with an extended magazine”

from his waistband. Acosta and Bourdosis returned to officers waiting in a police vehicle and drove

to where Garduza stood. When Acosta approached, Garduza and the other individual ran up the

stairs to the front door and entered a multifamily residence with the first floor elevated 6 to 10

steps. As Garduza did so, he held the firearm in his right hand. Acosta pursued, but the front door

was locked. Acosta unsuccessfully tried to force entry. Looking through a window just left of the

door, he made out “two silhouettes” running towards the back of the apartment.

¶9 Acosta and Bourdosis ran to a “back side door,” which was unlocked. Acosta opened it and

saw Garduza and the other individual atop a flight of stairs leading to a residence on the first floor.

They ran inside. Acosta followed and detained them in the living room. Also in the residence were

two other men, one woman, and a child. Garduza and the men were taken outside while officers

searched for Garduza’s weapon.

¶ 10 The State published a clip of video footage captured by Acosta’s body-worn camera, which

we have reviewed. Acosta testified that the footage’s time-stamp of 5:06 was six hours fast. The

video clip shows Acosta ordering men in the living room to the ground. For the remainder of the

clip, Acosta searches the living room and kitchen area. According to Acosta, his camera was

deactivated at 5:12:40. He did not recall exactly why he deactivated the camera but thought the

search would be unsuccessful. Acosta later learned that officers discovered a weapon. Acosta

identified a firearm and extended magazine as the weapon he had seen in Garduza’s possession.

¶ 11 Garduza was arrested and taken to the police station. Acosta advised Garduza of his

Miranda rights and Garduza indicated he understood them. About two hours later, Acosta spoke

-3- No. 1-23-0431

with Garduza again. He lied that Garduza’s fingerprints were found on the weapon. Garduza

admitted that he had the firearm and planned to fire it in the air at midnight. When he saw the

police, he ran into the residence and placed the firearm next to the toilet. He further admitted being

a “[r]egular soldier” of the Latin Kings gang for four years and explained his gang-related tattoos.

¶ 12 Acosta captured his interview with Garduza on his body-worn camera. The State published

the video, and we have reviewed it. In the interview, Acosta tells Garduza that Garduza’s

fingerprints were discovered on the firearm and asks if Garduza had been “busting out” in front of

the house. Garduza responds in the affirmative. Acosta asks who put the firearms behind the toilet,

and Garduza admits he did, pointing out that he planned to shoot it in the air at midnight for New

Year’s Eve and agrees that was “it,” as in the only reason he had the firearm. Acosta asks where

Garduza was a “king,” and Garduza says 23rd and Spaulding, for four years with the rank of

“soldier.” He had “LK” tattoos on his hands and a five-point crown on his arm. He nods when

asked if “LK” stands for “Latin Kings.”

¶ 13 Acosta testified that he was familiar with the Latin Kings, “a criminal street organization”

with over 10,000 members that committed crimes “such as racketeering, drug sales, drug

manufacturing, violent crimes, and armed robberies and carjackings.” Acosta gave examples of

the Latin Kings’ criminal activity of which he had personal knowledge. None of the examples

involved Garduza.

¶ 14 Acosta said that three people were in charge of every block in the Latin Kings’ territory,

an “Inca,” “Cassique,” and “Enforcer,” and explained their respective roles. As for signifiers

indicating membership in the Latin Kings, he spoke of tattoos such as “LK” and a five-pointed

crown as sometimes referring to the specific block the member was from. Acosta identified

-4- No. 1-23-0431

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Related

People v. Garduza
2026 IL App (1st) 230431-B (Appellate Court of Illinois, 2026)

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2024 IL App (1st) 230431-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-garduza-illappct-2024.