People v. Luchins

2025 IL App (1st) 221604-U
CourtAppellate Court of Illinois
DecidedApril 10, 2025
Docket1-22-1604
StatusUnpublished

This text of 2025 IL App (1st) 221604-U (People v. Luchins) 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. Luchins, 2025 IL App (1st) 221604-U (Ill. Ct. App. 2025).

Opinion

2025 IL App (1st) 221604-U No. 1-22-1604 Order filed April 10, 2025 Fourth 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. 18 CR 60185 ) MATTHEW LUCHINS, ) Honorable ) James Michael Obbish, Defendant-Appellant. ) Judge Presiding.

JUSTICE LYLE delivered the judgment of the court. Presiding Justice Rochford concurred in the judgement. Justice Ocasio dissented.

ORDER

¶1 Held: Defendant’s conviction is affirmed over his contentions that the trial court abused its discretion by barring him from asserting an affirmative defense of involuntary intoxication and failed to award him proper sentencing credit.

¶2 Following a bench trial, the defendant, Matthew Luchins, was found guilty of second-

degree murder (720 ILCS 5/9-2(a) (West 2018)) and sentenced to 14 years’ imprisonment. On

appeal, Matthew contends the trial court erred in denying him the chance to present a defense of No. 1-22-1604

involuntary intoxication, where, although he knowingly consumed portions of a cannabis edible,

he was unaware that it was laced with an adulterant that would cause him to enter a psychotic state.

He also asserts the court erred in denying him sentencing credit for his participation in self-

improvement programs while in pre-trial custody. For the following reasons, we affirm.

¶3 I. BACKGROUND

¶4 Matthew was charged with six counts of first-degree murder (720 ILCS 5/9-1(a) (West

2018)) in the stabbing death of his father, Daniel Luchins. Matthew filed an answer to discovery

and notified the State of his intent to present two affirmative defenses: (1) intoxicated or drugged

condition, or involuntary intoxication, under 720 ILCS 5/6-3 (West 2018); and (2) use of force in

defense of self or others under 720 ILCS 5/7-1 (West 2018).

¶5 Specifically, Matthew intended to argue that (1) his intoxication was involuntarily

produced because he unknowingly ingested an edible that contained an adulterant, and (2) he

lacked substantial capacity to appreciate the criminality of his conduct at the time of the incident.

Alternatively, he intended to argue that due to his intoxication, he believed that his actions were

in self-defense and in defense of his mother, Catherine Luchins. He tendered copies of two forensic

psychiatric examination reports to support his claim of involuntary intoxication.

¶6 A. Motion in limine

¶7 Prior to trial, the State filed a motion in limine to prevent Matthew from arguing the

affirmative defense of intoxicated or drugged condition. The argument on the motion was held

January 13, 2022. The State argued that the defense was not available to Matthew because his

intoxication was the result of his voluntary ingestion of an illegal substance. The State also asserted

that voluntary intoxication was not a valid legal defense in Illinois.

-2- No. 1-22-1604

¶8 In response, Matthew argued that the evidence would establish that his actions were the

result of substance-induced psychotic behavior. He maintained that the cause of his behavior was

“self-administered cannabis that was likely laced with ketamine or another adulterant.” During his

state of “involuntary intoxication,” he believed that he had to kill his father to save himself and his

mother. He argued that the involuntary act was “taking the substance as a whole not knowing what

else [was] in there.” Though he was not tested for ketamine or another adulterant at the time of the

incident, Matthew was prepared to present testimony of two psychiatrists at trial who would testify

that his self-reported state of mind and behavior were consistent with the effects of a substance

such as ketamine.

¶9 Additionally, Matthew argued that the State could not show that he consumed an illegal

substance because, at the time of the offense, possession of less than 10 grams of marijuana was a

“civil matter.” He asserted that 720 ILCS 5/6-3 did not specifically “address the legality or

illegality of a substance,” and that he should not be prevented from arguing involuntary

intoxication because he “ingested an allegedly illegal substance.”

¶ 10 On February 24, 2022, the trial court granted the State’s motion. The court stated that

voluntary intoxication was not a defense in the State of Illinois and observed that, according to the

proffer, Matthew voluntarily ingested cannabis prior to the murder. It noted that cannabis is taken

to “alter” a person’s state of mind or to “get into an intoxicated state or some sort of euphoric

state.” It further noted that the “most relevant factor” in this case was that Matthew “ingested that

substance voluntarily.” It stated that when “intentionally consuming an intoxicating substance” a

person is “assuming the risk of what that intoxicating substance is going to lead you to do,”

especially when a person consumes substances that are bought off the street.

-3- No. 1-22-1604

¶ 11 The trial court then addressed the two expert opinions speculating that the cannabis cookie

contained “ketamine or some other similar substance which caused [Matthew] to act in a way

differently from when he normally ingests an intoxicating substance such as cannabis.” The court

reasoned that the defense was attempting to argue that, because Matthew reacted differently this

time to taking cannabis, he should be able to claim that his drugged condition was involuntary

produced. It commented that, despite the expert opinions, without medical evidence that Matthew

had ketamine in his system, the admissibility of the expert testimony would depend on whether

the court allowed the affirmative defenses to be presented at all. It stated, “[e]ven if there was some

ketamine, I cannot divorce myself from the fact that [Matthew] voluntarily ingested a substance

designed to produce an intoxicating effect.”

¶ 12 The trial court ruled that the affirmative defense of involuntary intoxication was not

available to Matthew. However, it did grant his request to present the affirmative defense of self-

defense based on Matthew’s unreasonable belief that he had to kill his father to save himself and

his mother.

¶ 13 B. Trial

¶ 14 At the bench trial, Catherine, Matthew’s mother, testified that at the time of the incident,

she, Matthew, and her husband lived together. On the day of the incident, Matthew returned home

around midnight and that she could hear him and Daniel talking. Daniel then came into their

bedroom and told her that Matthew was in a “highly impaired state” and had something to tell

them.

¶ 15 Catherine went into the dining room with Daniel and Matthew. She stated that Matthew

was walking in a strange way, “like Frankenstein,” and was slapping himself. She and Daniel

-4- No. 1-22-1604

attempted to get Matthew to sit down because he was agitated and jittery.

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Bluebook (online)
2025 IL App (1st) 221604-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-luchins-illappct-2025.