People v. Houser

2022 IL App (1st) 201071-U
CourtAppellate Court of Illinois
DecidedDecember 21, 2022
Docket1-20-1071
StatusUnpublished

This text of 2022 IL App (1st) 201071-U (People v. Houser) 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. Houser, 2022 IL App (1st) 201071-U (Ill. Ct. App. 2022).

Opinion

2022 IL App (1st) 201071-U No. 1-20-1071 Order filed December 21, 2022 Third 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. 17 CR 02791 ) LOWELL HOUSER, ) Honorable ) William G. Gamboney, Defendant-Appellant. ) Judge, presiding.

PRESIDING JUSTICE McBRIDE delivered the judgment of the court. Justices Burke and D.B. Walker concurred in the judgment.

ORDER

¶1 Held: Defendant’s conviction for second degree murder is affirmed over his contention that the State did not prove beyond a reasonable doubt that his actions were not justified as self-defense. The trial court did not abuse its discretion in precluding defendant from presenting evidence of the victim’s aggressive and violent character that was remote in time from the instant offense.

¶2 Following a bench trial, defendant Lowell Houser was convicted of second degree murder

(720 ILCS 5/9-2(a)(2) (West 2016)) and sentenced to 10 years in prison. On appeal, defendant, an

off-duty police officer who claimed self-defense, challenges the sufficiency of the evidence, No. 1-20-1071

contending that the State failed to disprove justification where the victim angrily confronted him,

threatened to shoot him, and reached towards his rear waistband in the moments before the

shooting. Defendant also contends that the trial court erred in imposing a 10-year cutoff for

evidence of prior instances of the victim’s aggressive and violent character, rather than giving each

incident individualized consideration in determining its admissibility. For the reasons that follow,

we affirm.

¶3 Defendant’s conviction arose from the January 2, 2017, shooting death of Jose Nieves in

front of Nieves’s apartment building in Chicago. Following arrest, defendant was charged by

indictment with six counts of first degree murder.

¶4 Prior to trial, defendant filed a motion pursuant to People v. Lynch, 104 Ill. 2d 194 (1984),

seeking the admission of evidence of 10 prior incidents he alleged showed Nieves’s aggressive

and violent conduct. Defendant indicated that the defense was attempting to secure the cooperation

and presence at trial of witnesses who could testify regarding the incidents and stated that the

defense’s answer to discovery would be supplemented when those witnesses were located.

Defendant explained that he was presenting the motion “so that everyone is aware of the nature of

the evidence that [defendant] will attempt to present at trial.”

¶5 As an offer of proof, defendant provided information about the incidents that he had

gleaned from police reports. The 10 incidents were as follows: (1) on December 25, 1996, Nieves

threatened a woman that he would “blow her away” and he was arrested for assault; (2) on March

29, 1998, Nieves struck a man in the face, causing a laceration to his eye, and was charged with

battery; (3) on May 10, 1999, Nieves yelled profanities and flashed gang signs at men in a rival

gang and was charged with disorderly conduct; (4) on September 21, 1999, Nieves screamed gang

-2- No. 1-20-1071

slogans, flashed gang signs, told officers “f*** the police,” and was arrested for mob action; (5)

on March 17, 2000, Nieves threw several punches at a man, threw a brick at the man’s door, and

was charged with assault and criminal damage to vehicle; (6) on December 7, 2001, Nieves went

to a former employer’s business, threatened to kill the owner and blow up the manager’s home,

and was arrested for two counts of assault; (7) on December 15, 2006, Nieves was arrested because

he had an outstanding warrant for violating an order of protection; (8) on January 13, 2008, Nieves

struck his wife in the face, attempted to strangle her, swung a knife at her, and was arrested for

domestic battery; (9) on June 22, 2012, Nieves argued with two women on a sidewalk while he

had a pellet or BB gun in his front waistband and was charged with a city ordinance violation; and

(10) on January 28, 2013, Nieves slapped his ex-girlfriend in the head and ear, causing a red mark;

she signed a complaint against him for domestic battery; and lock-up staff noted Nieves was “very

hostile and abusive” during booking.

¶6 The State filed a response, arguing that the Lynch material should be barred. The State

asserted that there was no evidence of self-defense, that defendant did not know Nieves’s criminal

history at the time of the shooting, that Nieves was not armed, and that Nieves was not the initial

aggressor. The State further argued that the prior incidents of Nieves’s behavior were remote in

time, with only three falling within a 10-year period preceding the current charge, and that at least

three of the incidents did not involve “crimes of violence.” Finally, noting that none of the incidents

resulted in convictions, the State asserted that mere arrests did not meet the level of reliability

mandated by Lynch.

¶7 The trial court held a hearing on the Lynch motion on April 4, 2019. At the hearing, defense

counsel reiterated that the motion was based on a preliminary investigation and arrest reports, and

-3- No. 1-20-1071

that the defense understood witness testimony regarding the incidents would be required at trial.

As to the fact that the majority of the incidents occurred more than 10 years prior to the instant

offense, defense counsel maintained that their age “cut[ ] the other way,” as they “show[ed] the

longstanding, almost ingrained pattern of violent, threatening behavior by Mr. Nieves.” Counsel

also argued that “the fact that some of the cases go back a number of years actually is proof of how

compelling this evidence is.”

¶8 The State argued that the prior incidents were remote in time, uncertain, and unduly

prejudicial. The State also reiterated its positions that, because none of the incidents resulted in a

conviction, they did not meet the level of reliability mandated by Lynch, and that the incidents not

involving crimes of violence were not allowed under Lynch.

¶9 Citing People v. Ellis, 187 Ill. App. 3d 295 (1989), the trial court ruled that the incidents

that occurred more than 10 years prior to the shooting were inadmissible. It reserved ruling on the

admissibility of the three more recent incidents, stating, “[W]e’ll just have to see how this plays

out. We can revisit it at the time of trial.”

¶ 10 Defendant’s bench trial commenced on October 29, 2019.

¶ 11 Michelle Malkowski testified that she had been in a dating relationship with Nieves for 12

years. On the morning in question, she was helping him move some of his belongings from a

storage unit to his second-floor apartment. He was wearing a camouflage jacket, a t-shirt, jeans,

and a belt. His shirt was tucked in and his jacket was open. Nieves was not carrying a gun or any

other weapon.

¶ 12 Around 9 a.m., Malkowski and Nieves arrived at his building in separate cars and parked

on the street. After they took some boxes inside, Malkowski headed back outside to her car. She

-4- No. 1-20-1071

encountered defendant, who was also leaving the building.

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Related

Jackson v. Virginia
443 U.S. 307 (Supreme Court, 1979)
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2022 IL App (1st) 201071-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-houser-illappct-2022.