People v. Martin

• Court: Appellate Court of Illinois
• Decided: June 9, 2026
• Docket: 5-25-0287
• Status: Unpublished

Opinion

NOTICE 2026 IL App (5th) 250287-U NOTICE Decision filed 06/09/26. The This order was filed under text of this decision may be NO. 5-25-0287 Supreme Court Rule 23 and is changed or corrected prior to not precedent except in the the filing of a Petition for IN THE limited circumstances allowed Rehearing or the disposition of under Rule 23(e)(1). the same. APPELLATE COURT OF ILLINOIS

FIFTH DISTRICT ______________________________________________________________________________

THE PEOPLE OF THE STATE OF ILLINOIS, ) Appeal from the ) Circuit Court of Plaintiff-Appellee, ) Marion County. ) v. ) No. 23-DV-49 ) JEREMIAH MARTIN, ) Honorable ) Mark W. Stedelin, Defendant-Appellant. ) Judge, presiding. ______________________________________________________________________________

JUSTICE HACKETT delivered the judgment of the court. Presiding Justice Cates and Justice Moore * concurred in the judgment.

ORDER

¶1 Held: We affirm the defendant’s conviction for domestic battery where the trial evidence was sufficient for a rational trier of fact to find the defendant guilty beyond a reasonable doubt.

¶2 Following a bench trial, the defendant, Jeremiah Martin, was convicted of domestic battery

(720 ILCS 5/12-3.2(a)(2) (West 2022)) and sentenced to one year of probation. On appeal, the

defendant argues that we must reverse his conviction outright where the State failed to prove him

guilty beyond a reasonable doubt. For the following reasons, we affirm.

¶3 I. BACKGROUND

* Justice Moore fully participated in the decision prior to his retirement. See Cirro Wrecking Co. v. Roppolo, 153 Ill. 2d 6 (1992). 1 ¶4 On September 22, 2023, the defendant was charged via information with one count of

domestic battery, a Class A misdemeanor. On January 25, 2024, the defendant waived his right to

a jury trial. At the bench trial on January 23, 2025, the following testimony was adduced.

¶5 Dakota N. testified that on September 21, 2023, he was 14 years old and lived in Salem

with his sister and mother, Jamie N. The defendant, Jamie’s partner of nine years, also lived with

them. Although Jamie and the defendant were not married, Dakota referred to the defendant as his

stepfather.

¶6 Dakota testified that on the evening of the incident, Jamie left the house to pick up dinner

from McDonald’s. While Jamie was gone, Dakota rode Jamie’s bicycle to go talk to the neighbors.

When Dakota returned home six minutes later, he jumped off the bike as it was still moving, an

action referred to as “ghosting” the bike. The defendant, who was on the porch drinking beer,

yelled at Dakota for ghosting the bike and told Dakota to put the bike away in its spot. Dakota put

the bike away and walked up the house’s front steps with clenched fists. At that point, Jamie

arrived back at the house.

¶7 Dakota testified that the defendant followed Dakota into the living room, pushed Dakota,

and said, “Let’s go.” Dakota then yelled back, “You want to fight me, let’s go.” Dakota threw his

glasses at the defendant before he and the defendant attempted to wrestle each other to the ground.

Dakota was not sure who first made physical contact. Before either could succeed in wrestling the

other to the ground, Jamie grabbed the defendant, who was three or four feet away from Dakota.

Leaning against Jamie, the defendant lifted his foot and kicked Dakota in the mouth. After the

kick, Jamie pulled the defendant outside, and Dakota’s sister brought Dakota to his room. Dakota

had scratches on his face and pinch marks on his right side.

2 ¶8 Jamie N. testified that in the early evening of September 21, 2023, she and the defendant

were sitting on the porch talking. The defendant was drinking beer and smoking. According to

Jamie, the defendant usually got home from work at around 6 p.m. and drank a 12-pack of beer

nightly. The defendant asked Jamie to get him food from McDonald’s, so Jamie took her daughter

and left while it was still light outside. Jamie estimated that they were gone for 15 minutes. When

Jamie returned, she noticed that the defendant had changed out of his work clothes and looked

“agitated and puffy.” Jamie instantly knew from the defendant’s posture that something was

wrong. As she arrived, the defendant told Jamie that Dakota had taken her bike and left the house

without permission. Dakota then returned, and the defendant told Dakota to put the bike away and

go inside. Dakota “ghosted” the bike and let it go into the open garage. The defendant yelled at

Dakota about his treatment of the bike and told Dakota to go inside.

¶9 As Dakota went up the steps and into the house, the defendant followed him and continued

yelling at him. Dakota was not yelling back. Jamie followed “a split second” behind Dakota and

the defendant. When she got to the living room, she “saw what looked like [the defendant] going

to kick [Dakota].” The defendant was standing on his right leg with his left leg “up off of the

ground,” as though he “was about to try to kick [Dakota] in the face.” Jamie immediately grabbed

the defendant and pulled him away from Dakota. When asked whether she witnessed any physical

contact between Dakota and the defendant, Jamie stated: “I honestly don’t recall the real specifics.

What remains is just [the defendant’s] leg was up, and I took it as him going to hurt Dakota.” On

cross-examination, Jamie testified that she did not witness contact being made but did hear a noise.

Jamie’s daughter took Dakota into the kitchen and called the police. The defendant stayed out on

the porch and did not reenter the house. Jamie examined Dakota and observed a scratch near his

eye. Dakota’s glasses and necklace were broken, and the necklace was on the living room floor.

3 ¶ 10 Jamie confirmed that the defendant shared in parental responsibilities with her and

disciplined her children “from time to time,” but that she had “the final say.” Jamie testified that

the defendant “always had a very set idea of how the kids should be disciplined.” If Jamie disagreed

with the defendant, he would tell Jamie that she should not disagree because Dakota would not

learn otherwise.

¶ 11 Officer Ryan Meador testified that, on September 21, 2023, he was on duty as a Salem

police officer and responded to a domestic disturbance call at 412 South Washington. He arrived

at around 6:55 p.m. and walked up to the house. He heard yelling between the defendant and a

female. Office Meador knocked on the door, and the defendant answered the door with a beer in

his hand. The defendant put the beer on the counter before stepping outside on the patio to speak

with Officer Meador. The defendant told Officer Meador that his 14-year-old stepson had not been

listening to him, and that they had gotten into a disagreement. At first, the defendant denied

touching Dakota at all; later, he stated that he pushed Dakota because Dakota threw his glasses at

him. The defendant told Officer Meador that Dakota’s necklace was broken because it “had gotten

wrapped up in [the defendant’s] fingers” when he pushed Dakota. Another officer, Officer King,

who had gone inside the residence, then came outside and advised Officer Meador that Dakota had

marks on his face consistent with battery. Officer Meador placed the defendant under arrest.

Officer Meador observed marks on Dakota’s face and saw that Dakota’s glasses were broken.

Officer Meador took photographs of Dakota’s face, right shoulder, broken glasses, and broken

necklace. At trial, all of the photographs were admitted into evidence without objection.

¶ 12 At this point, the State rested, and defense counsel moved for a directed verdict, arguing

that the witnesses’ testimonies were too inconsistent for the State to prove the defendant guilty

beyond a reasonable doubt. The trial court denied the motion.

4 ¶ 13 The defendant testified that on September 21, 2023, he bought a six-pack of beer on his

way home from work. He arrived home and drank on the porch while talking to Jamie. Just after

he opened his second beer, Jamie left to get food. At the time, Dakota was grounded for not doing

his chores, and Jamie had agreed to this punishment. The defendant testified that he and Jamie had

consistent problems with Dakota. While the defendant was still sitting on the porch, Dakota got

on Jamie’s bike and rode down the street. Dakota did not ask the defendant for permission before

leaving. After a couple of minutes, the defendant “yelled at [Dakota] to get his ass home.” At that

point, Dakota returned home.

¶ 14 Dakota reached the yard, “jumped off the bike[,] and shoved it in the garage,” at which

point the defendant and Dakota began arguing. Dakota “balled up his fists” and walked up the

house steps, and the defendant followed behind. At this point, Jamie arrived back at the house. The

defendant and Dakota entered the house and eventually reached the living room. There, the

defendant reached out, put his hand on Dakota’s shoulder, and said, “Hey, just stop it.” Dakota

then turned around and swung at the defendant but missed because the defendant leaned back. The

defendant then grabbed Dakota by the shoulders. The defendant bent Dakota over and yelled for

Jamie to come into the house. Jamie grabbed the defendant’s arm and yanked him backwards, at

which point Dakota “smacked himself in the face and ripped the glasses off and threw them at”

the defendant. Jamie took the defendant to the door, where the defendant yelled at Jamie. The

police then arrived.

¶ 15 The defendant was not sure what had happened to the necklace and testified that he did not

even know about the necklace until the trial. The defendant denied pinching, hitting, or kicking

Dakota. The defendant testified that neither he nor Dakota were on the ground. The defense then

rested.

5 ¶ 16 In its oral ruling, the trial court described Dakota’s testimony as “fairly credible” and

“direct”; Jamie’s testimony as similarly direct; and Officer Meador’s testimony as “direct and

credible.” The court described the “form and substance” of the defendant’s testimony as “fairly

credible” and “direct.” However, the trial court commented that the defendant’s testimony was

“entirely inconsistent” with Jamie’s and Dakota’s testimonies that, at the very least, the

defendant’s leg was raised in a kicking position. The trial court also noted that the defendant

claimed at trial “that he didn’t know what happened to the necklace, even though he told the police

that his hand got tangled up in the necklace.” The trial court concluded that Dakota’s testimony

was “more credible than the defendant’s.” The trial court found the defendant guilty of domestic

battery.

¶ 17 On February 24, 2025, the defendant filed a motion to vacate judgment and a motion for

judgment notwithstanding the verdict, arguing in both that the State had failed to prove him guilty

of domestic battery beyond a reasonable doubt. On March 6, 2025, the trial court denied both

motions and sentenced the defendant to one year of probation. The defendant appeals.

¶ 18 II. ANALYSIS

¶ 19 On appeal, the defendant argues that this court must reverse his domestic battery conviction

outright where the State failed to prove him guilty beyond a reasonable doubt. Due process protects

an accused against conviction except upon proof beyond a reasonable doubt of every fact necessary

to constitute the crime with which he is charged. U.S. Const., amend. XIV; Ill. Const. 1970, art. I,

§ 2. When reviewing the sufficiency of the evidence, the standard is whether, viewing the evidence

in the light most favorable to the prosecution, any rational trier of fact could have found the

essential elements of the crime beyond a reasonable doubt. People v. Cunningham, 212 Ill. 2d 274,

278-79 (2004); see Jackson v. Virginia, 443 U.S. 307, 319 (1979). Following a finding of guilt, on

6 review, all reasonable inferences in the record will be made in favor of the State. Cunningham,

212 Ill. 2d at 280. So long as any rational trier of fact could have found guilt established beyond a

reasonable doubt, it is irrelevant on review whether the reviewing court itself believes such guilt

was proven. Jackson, 443 U.S. at 319.

¶ 20 “When presented with a challenge to the sufficiency of the evidence, it is not the function

of this court to retry the defendant.” People v. Collins, 106 Ill. 2d 237, 261 (1985). The

determination of the witnesses’ credibility and the weight of their testimony, the resolution of

conflicts in the evidence, and the deriving of reasonable inferences from the evidence are within

the province of the trier of fact. People v. Brooks, 187 Ill. 2d 91, 132 (1999). A reviewing court

will not substitute its judgment for that of the trier of fact on these matters. Id. However, this

deference to the trial court only extends to reasonable conclusions; if a court’s conclusion is

unreasonable, and “only one conclusion may reasonably be drawn from the record, a reviewing

court must draw it even if it favors the defendant.” Cunningham, 212 Ill. 2d at 280.

¶ 21 To sustain a charge of domestic battery, the State must prove that the defendant knowingly,

and without legal justification, made physical contact of an insulting or provoking nature with a

family or household member. See 720 ILCS 5/12-3.2(a)(2) (West 2022). While the physical

contact must have been of an insulting or provoking nature, it does not need to have caused

physical injury. People v. Green, 2011 IL App (2d) 091123, ¶ 23.

¶ 22 Here, the defendant challenges only whether the specific physical contact of which he was

accused, kicking Dakota in the face, actually occurred. The defendant does not dispute that such

contact would have been done knowingly and without legal justification, or that it would have

been of an insulting or provoking nature. The defendant similarly does not dispute that Dakota was

a family or household member. Therefore, we only consider whether, viewing the evidence in the

7 light most favorable to the State, any rational trier of fact could have found beyond a reasonable

doubt that the defendant kicked Dakota in the face.

¶ 23 Dakota, Jamie, and the defendant all agreed on some of the facts from the incident: the

defendant was drinking that evening, the argument concerned Dakota’s leaving the house on

Jamie’s bike and “ghosting” the bike upon his return to the house, the defendant yelled at Dakota

for his behavior, the defendant followed Dakota up the steps into the house, Jamie entered the

house at some point after Dakota and the defendant, and the altercation ultimately ended when

Jamie pulled the defendant away from Dakota.

¶ 24 The defendant and Dakota also agreed that Dakota clenched his fists while walking up the

stairs and threw his glasses at the defendant inside the house. Dakota admitted that he did not recall

whether he or the defendant first made physical contact. Officer Meador testified that, at the time

of the incident, the defendant initially denied any physical contact with Dakota before admitting

to pushing Dakota because Dakota threw his glasses at him, and to breaking Dakota’s necklace in

the push. At trial, however, the defendant never testified about pushing Dakota at any point,

including after Dakota threw his glasses at the defendant. The defendant also denied any

knowledge about the necklace.

¶ 25 The witnesses’ testimonies significantly differ on the critical point of the kick. Dakota

testified that the defendant lifted his foot off the ground and kicked Dakota in the mouth. Jamie

testified that, although she did not witness contact being made, she heard a noise and saw the

defendant’s leg lifted off the ground and aimed in a kicking position toward Dakota’s face. The

defendant was the sole party present during the altercation that did not testify that, at the very least,

at some point during the altercation, his foot was raised off the ground and aimed in a kicking

position toward Dakota’s face.

8 ¶ 26 The trial court, hearing all of the testimony, determined the witnesses as all fairly credible,

but ultimately resolved the conflicts in their testimonies against the defendant and assigned more

weight to Dakota’s testimony than to the defendant’s. Since, in a bench trial, the trial court serves

as the trier of fact, to make such determinations is well within the court’s province. We do not find

that the trial court’s conclusions were unreasonable, or that the evidence, considered in the light

most favorable to the State, was so insufficient that no rational trier of fact could have found the

defendant guilty of domestic battery beyond a reasonable doubt. We decline to reweigh the

evidence or retry the defendant here.

¶ 27 III. CONCLUSION

¶ 28 When considered in the light most favorable to the State, the trial evidence was sufficient

for a rational trier of fact to find the defendant guilty of domestic battery beyond a reasonable

doubt. The defendant’s conviction is affirmed.

¶ 29 Affirmed.