People v. Medley

444 N.E.2d 269, 111 Ill. App. 3d 444, 67 Ill. Dec. 230, 1983 Ill. App. LEXIS 1378
CourtAppellate Court of Illinois
DecidedJanuary 6, 1983
Docket4-82-0043
StatusPublished
Cited by23 cases

This text of 444 N.E.2d 269 (People v. Medley) 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. Medley, 444 N.E.2d 269, 111 Ill. App. 3d 444, 67 Ill. Dec. 230, 1983 Ill. App. LEXIS 1378 (Ill. Ct. App. 1983).

Opinion

JUSTICE MILLS

delivered the opinion of the court:

The facts in this case are singularly odious and repulsive.

Four acts of rape, two anal assaults, and four acts of fellatio — all committed on a young housewife by two home invaders.

A jury found Medley guilty of rape, home invasion, and burglary, and he received concurrent sentences of 45-45-7 years.

We affirm.

In the early hours of a hot June morning, a husband, his wife, their infant son and nine-year-old niece were asleep in their home in Springfield. The husband was awakened by the sound of the screen door opening. When he went to investigate, he saw a man standing over his niece who was asleep on the front room couch. The husband yelled and turned to run for the kitchen. A second man intercepted him, placed a gun to his head and ordered him to be quiet. In all, there were three intruders in the victims’ home — two men and a woman. (During the remainder of the events described herein, the female intruder stayed in the front room of the home, watching over the niece.)

The second man then forced the husband into the bathroom and threatened his life and those of his family if he attempted to escape. During this time, the wife came out of the bedroom to investigate the commotion. The first man forced her back into the bedroom, ordered her to undress, and raped her. While the rape was taking place, the couple’s three-month-old son, who was asleep on the bed, began to cry. The intruder ordered the wife to quiet the baby so she began to nurse her son.

The two men then took turns raping the wife and ransacking the home. The wife was raped four times, assaulted anally twice, and forced to perform four acts of fellatio. During these attacks, the wife was nursing her infant son in an attempt to keep him quiet. When the intruders were finished, they tied and gagged the victims and then fled with the couple’s car, credit cards, and several items of personal property. Four days later, Medley confessed to being one of the intruders. A jury convicted him of rape, home invasion, and burglary.

I

Medley argues that the prosecution and the trial judge committed several errors which require reversal of his conviction. He argues first that his confession should not have been admitted into evidence because it was the product of an illegal detention, and contends that his detention was illegal because the police failed to take him before a judge without unnecessary delay. We disagree. Medley was not illegally detained. While he was being questioned concerning an unrelated shooting incident, the police received information that he was involved in the present crimes. When confronted with this information, Medley confessed and then led the police to the house where the stolen goods were located. All of this took place during a period of legal detention.

Even if Medley had been illegally detained, it would not have been error to admit his confession. Failure to bring a defendant before a judge without unnecessary delay will not render a confession per se invalid. (People v. Zepeda (1970), 47 Ill. 2d 23, 265 N.E.2d 647.) In Illinois, courts determine the admissibility of a confession by deciding whether or not it was given voluntarily. (People v. Dees (1981), 85 Ill. 2d 233, 422 N.E.2d 616.) Unnecessary delay is only one of the factors which the courts consider. (People v. Taylor (1968), 40 Ill. 2d 569, 241 N.E.2d 409.) It is clear from the record that Medley gave his confession voluntarily and thus it was not error to admit it into evidence.

II

Next, Medley argues that it was error for the trial judge to require him to appear before the jury clad in jail clothing. In People v. Wilkes (1982), 108 Ill. App. 3d 460, 438 N.E.2d 1385, this court held that it was error to force a defendant to appear before the jury while dressed in jail clothing. In that case, the defendant was forced to appear before the jury dressed in bright orange coveralls with the word “jail” stenciled across the back. The situation in the case before us is not nearly as egregious. The jail clothing which Medley wore was pale green and consisted of a pair of pants and a pullover shirt similar to that worn by surgeons. Furthermore, Medley had ample opportunity to obtain civilian clothing before his trial. Instead, he waited until the moment before the trial was to begin and then requested a continuance so that he could obtain other clothing. Such behavior cannot be condoned. The wheels of justice grind slowly enough without allowing defendants to use this type of delaying tactic. We find that it was not error for the trial judge to require Medley to appear briefly before the jury while he was dressed in routine jail clothing.

Even if it was error, it would be harmless error. In Wilkes, we adopted a three-pronged approach to determine whether forcing a defendant to wear identifiable jail clothing constituted harmless error. In order to find whether the error was harmless, we first focus on the error and decide whether or not it contributed to the conviction. Second, we determine whether the evidence supporting the conviction is overwhelming. Finally, we decide whether the error merely duplicates other properly admitted evidence. Forcing Medley to appear before the jury in jail clothing would have been harmless error under all three aspects. It is doubtful that such an error contributed to his conviction because the evidence supporting his conviction was overwhelming and because Medley, during direct examination, informed the jury that he was in custody at the jail. Hence, any information conveyed to the jury by his jail clothing would have been merely duplicitous.

Ill

Medley also argues that five of the remarks made by the prosecution during the trial constituted reversible error.

We disagree.

First, Medley argues that it was reversible error for the prosecution to state during its closing argument that Medley’s confession met all of the necessary legal requirements. The prosecution's statement was not error. During his direct examination, Medley raised several issues concerning the legal sufficiency of his confession. The prosecution was merely commenting on those issues. Furthermore, the policy behind not allowing either side to argue the legality of a confession to a jury is to prevent the jury from confusing the confession’s legal credibility with its factual credibility. (See People v. Monroe (1981), 95 Ill. App. 3d 807, 420 N.E.2d 544; People v. Carter (1979), 73 Ill. App. 3d 406, 392 N.E.2d 188.) In the case before us, the prosecution explicitly told the jury several times that it was their duty to consider all of the evidence and to determine for themselves the weight that should be given to the confession.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

People v. Crandell
2025 IL App (3d) 230432-U (Appellate Court of Illinois, 2025)
People v. Alexander
2024 IL App (3d) 210575-U (Appellate Court of Illinois, 2024)
People v. Fleming
2023 IL App (1st) 211171-U (Appellate Court of Illinois, 2023)
People v. Bowman
2012 IL App (1st) 102010 (Appellate Court of Illinois, 2012)
People v. Mazar
775 N.E.2d 135 (Appellate Court of Illinois, 2002)
People v. Mazar (Nunc Pro Tunc June 28, 2002)
Appellate Court of Illinois, 2002
People v. Wilder
749 N.E.2d 357 (Appellate Court of Illinois, 2001)
People v. Steinmetz
Appellate Court of Illinois, 1997
People v. King
538 N.E.2d 230 (Appellate Court of Illinois, 1989)
People v. Nightengale
523 N.E.2d 136 (Appellate Court of Illinois, 1988)
People v. Carter
522 N.E.2d 653 (Appellate Court of Illinois, 1988)
People v. Partee
511 N.E.2d 1165 (Appellate Court of Illinois, 1987)
People v. Hicks
501 N.E.2d 1027 (Appellate Court of Illinois, 1986)
People v. Kokoraleis
501 N.E.2d 207 (Appellate Court of Illinois, 1986)
People v. Redman
490 N.E.2d 958 (Appellate Court of Illinois, 1986)
People v. Campbell
467 N.E.2d 1112 (Appellate Court of Illinois, 1984)
People v. Johnson
461 N.E.2d 585 (Appellate Court of Illinois, 1984)

Cite This Page — Counsel Stack

Bluebook (online)
444 N.E.2d 269, 111 Ill. App. 3d 444, 67 Ill. Dec. 230, 1983 Ill. App. LEXIS 1378, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-medley-illappct-1983.