People v. Gayden

2020 IL App (1st) 162636-U
CourtAppellate Court of Illinois
DecidedJune 26, 2020
Docket1-16-2636
StatusUnpublished

This text of 2020 IL App (1st) 162636-U (People v. Gayden) 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. Gayden, 2020 IL App (1st) 162636-U (Ill. Ct. App. 2020).

Opinion

2020 IL App (1st) 162636-U

SIXTH DIVISION June 26, 2020

No. 1-16-2636

NOTICE: This order was filed under Supreme Court Rule 23 and may not be cited as precedent by any party except in the limited circumstances allowed under Rule 23(e)(1).

IN THE APPELLATE COURT OF ILLINOIS FIRST JUDICIAL DISTRICT

THE PEOPLE OF THE STATE OF ILLINOIS, ) Appeal from the ) Circuit Court of Plaintiff-Appellee, ) Cook County. ) v. ) No. 10 CR 18156 ) SAMUEL GAYDEN, ) Honorable ) Domenica A. Stephenson, Defendant-Appellant. ) Judge Presiding.

PRESIDING JUSTICE MIKVA delivered the judgment of the court. Justices Cunningham and Connors concurred in the judgment.

ORDER

¶1 Held: Convictions affirmed where (1) admission of DNA evidence was not an abuse of discretion, (2) opinion identification testimony of three witnesses was properly admitted, (3) prior inconsistent statements of a witness were properly admitted as substantive evidence, and (4) defendant did not receive ineffective assistance of counsel.

¶2 Defendant Samuel Gayden was convicted by a jury of two first degree murders and one

attempted first degree murder. He was sentenced to natural life in prison for the murders and 20

years for the attempted murder. On appeal, Mr. Gayden argues that he was deprived of a fair trial No. 1-16-2636

because the trial court erred by (1) allowing the State to use DNA evidence to tie Mr. Gayden to

the gun used in the shootings and letters sent from the jail, (2) allowing three witnesses to identify

him on surveillance video even though they did not witness the shooting, and (3) allowing the

State to present the prior statements of a witness. Mr. Gayden also argues that he received

ineffective assistance of trial counsel. For the following reasons, we affirm.

¶3 I. BACKGROUND

¶4 Just after midnight on September 1, 2010, three men were shot while inside State Garden

Food & Liquors in Chicago, Illinois. Two of them—Marcus Marshall and Shawntelle Harris—

died. The shooting was caught on the store’s surveillance cameras. Mr. Gayden was tried for first

degree murder with respect to Mr. Marshall and Mr. Harris, and attempted murder with respect to

the third man, Chauncey Williams.

¶5 A. Pre-Trial Motions and Rulings

¶6 Mr. Gayden filed numerous motions prior to trial. The following motions are relevant to

this appeal.

¶7 1. Motions to Bar Witness Identifications

¶8 Mr. Gayden sought to bar Akram Jaber, Lolita Garnett, Brian Murdock, Sergeant Jose

Lopez, and Chauncey Williams from identifying him on the surveillance videos because they did

not observe the shooting.

¶9 At the hearing, the State had agreed that Mr. Jaber and Ms. Garnett would not identify Mr.

Gayden on the surveillance video. The court ruled, over Mr. Gayden’s objection, that they could

testify as to what was in the video because they were present at the time of the shooting. The court

also ruled that Mr. Murdock would be permitted to identify Mr. Gayden in the video because he

was familiar with Mr. Gayden. The court then held a separate hearing to determine whether

2 No. 1-16-2636

Sergeant Lopez would be allowed to identify Mr. Gayden in the video.

¶ 10 At that hearing, Sergeant Lopez testified that he had known Mr. Gayden as “Duke” since

2007 from the neighborhood, had spoken to Mr. Gayden “a half a dozen times,” and was present

when Mr. Gayden was arrested for an unrelated offense in 2007.

¶ 11 The trial court concluded that Sergeant Lopez could identify Mr. Gayden in the video

because “Sergeant Lopez had sufficient knowledge of [Mr. Gayden] and [Mr. Gayden]’s

appearance prior to the incident that is depicted in the video.”

¶ 12 2. Motion to Bar DNA Evidence from the Envelope

¶ 13 Mr. Gayden sought to bar DNA evidence as to the testing done on two letters sent from

jail—purportedly by Mr. Gayden. The State had filed a motion to introduce the letters as evidence

of other crimes and argued the letters were relevant to show Mr. Gayden’s consciousness of guilt.

Mr. Gayden argued that the results of the DNA testing were “too incomplete and fragmented for

any conclusions as to identity to be made.”

¶ 14 At the hearing on the motion, Dr. Karl Reich testified as an expert for Mr. Gayden. The

doctor explained that there are 13 chromosome regions that can be analyzed in DNA testing, called

“loci,” but that there is no standard number of loci that need to match in order to make an

identification. Dr. Reich testified that according to the Illinois State Police (ISP) lab, one envelope

did not yield enough results for comparison. For the other envelope, the lab described receiving

results from six loci and a “sex locus,” which was used to determine that the letter came from a

man. Dr. Reich explained that the ISP lab compared four of the six loci to a sample collected from

Mr. Gayden. According to Dr. Reich, four loci was “not sufficient genetic identification

information to provide any conclusion on identity.” Dr. Reich acknowledged that Mr. Gayden

could not be excluded as a contributor and that the report concluded that approximately 1 in 6.2

3 No. 1-16-2636

million black individuals could not be excluded from having contributed to the DNA profile.

¶ 15 The trial court denied Mr. Gayden’s motion, finding that his objections went to the weight

of the evidence, rather than admissibility.

¶ 16 3. Motion In Limine to Bar DNA Evidence from the Recovered Gun

¶ 17 Mr. Gayden also filed a motion in limine to bar two DNA reports from swabs taken from

a gun recovered by the police from where he lived at the time during their investigation. The first

DNA report stated that the low-level DNA profile identified did not “contain enough information

to either exclude or imply positive association to Samuel Gayden.” The second report, completed

approximately four years later, employed a different method of quantifying DNA comparisons and

concluded that Mr. Gayden “c[ould] not be excluded,” and gave a probability that “one in four

black, one in three white, [and] one in four Hispanic” individuals could also not be excluded.

¶ 18 The trial court denied this motion as well, finding that the probative value of the DNA

results outweighed any prejudicial effect.

¶ 19 4. Mr. Jaber’s Identification Testimony

¶ 20 Just before voir dire of the jury began on May 16, 2016, the State indicated that it, in fact,

did want Mr. Jaber to identify Mr. Gayden on the surveillance video. Defense counsel responded

that, under the recent supreme court decision in People v. Thompson, 2016 IL 118667, a hearing

was necessary prior to his testifying. The court agreed to a hearing but said, prior to the hearing,

that it would allow Mr. Jaber to identify Mr. Gayden in the video if the evidentiary hearing

confirmed what the State had indicated Mr. Jaber would say.

¶ 21 At the evidentiary hearing, Mr. Jaber was shown a still from the video surveillance and

said that he recognized the shooter as one of the store’s regular customers who had come in

“[a]lmost daily” for “a long time, maybe five” years. Mr. Jaber said that he observed that person

4 No. 1-16-2636

inside the store right before the shooting occurred. Mr. Jaber also identified a photograph of Mr.

Gayden from the time of his arrest as the shooter from the video. Mr. Jaber said, however, he was

not able to identify the person from the photographs in the courtroom.

¶ 22 The trial court ruled that Mr.

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2020 IL App (1st) 162636-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-gayden-illappct-2020.