People v. Minnis

CourtAppellate Court of Illinois
DecidedMay 8, 2026
Docket1-23-2494
StatusPublished

This text of People v. Minnis (People v. Minnis) 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. Minnis, (Ill. Ct. App. 2026).

Opinion

2026 IL App (1st) 232494 No. 1-23-2494 Opinion filed May 8, 2026

FIFTH DIVISION

IN THE

APPELLATE COURT OF ILLINOIS

FIRST DISTRICT

THE PEOPLE OF THE STATE OF ) Appeal from the Circuit Court ILLINOIS, ) of Cook County. ) Plaintiff-Appellee, ) ) v. ) No.16 CR 13463 ) ALEEM MINNIS, ) ) The Honorable Defendant-Appellant. ) Angela Munari Petrone, ) Judge, presiding.

JUSTICE ODEN JOHNSON delivered the judgment of the court, with opinion. Presiding Justice Mitchell and Justice Wilson concurred in the judgment and opinion.

OPINION

¶1 Defendant Aleem Minnis was convicted after a jury trial of 2 counts of aggravated

kidnapping and 12 counts of aggravated criminal sexual assault. The counts stemmed from an

attack in the early morning hours on June 26, 2016, when defendant forced his way into the

victims’ car at gunpoint and sexually assaulted each of the two female victims multiple times.

Defendant was sentenced to a total of 96 years with the Illinois Department of Corrections

(IDOC). No. 1-23-2494

¶2 On appeal, defendant claims (1) that the trial court abused its discretion when it rejected

his request, made shortly before trial, to substitute a counsel who was not ready for trial;

(2) that the trial court erred in denying defendant’s pretrial motion to suppress the identification

testimony of the two victims, where the police failed to instruct the witnesses not to speak with

each other between identifications, where the police used the same photo array in both

identification procedures, although conducted at different locations, on different days, and

before different administrators, and where the witnesses did speak to each other before the

second procedure, although not about the photo selected; and (3) that defendant’s 96-year

sentence was excessive, where defendant was 23 years old with rehabilitative potential and

where the trial court allegedly held defendant’s assertions of innocence against him. For the

following reasons, we do not find these arguments persuasive and affirm.

¶3 BACKGROUND

¶4 On appeal, defendant does not argue that the evidence at trial was insufficient to convict

him; therefore, we summarize it below.

¶5 The evidence at trial established that the two victims, L.B.E. and B.M., both aged 31

years old, drove to a sub shop at 2 a.m. on June 26, 2016, where they ordered food. While they

were in the shop, defendant tried to talk to L.B.E., asked for her number, and tried to give her

his number. In response, L.B.E. pretended to put a number in her phone. After retrieving their

order, the two women returned to B.M.’s car, with B.M. entering the driver’s side and L.B.E.

entering the front passenger’s side. Defendant approached and stood with a gun drawn, such

that L.B.E. could not close her door. Defendant told them he would shoot if they screamed,

and he entered the back seat behind L.B.E. While holding the gun, he directed B.M. to drive

to a nearby vacant parking lot one block away and park near a dumpster, where he ordered

2 No. 1-23-2494

them to remove their clothes. While holding the gun in one hand, he used the other hand and

his mouth to open a condom wrapper, and he put a condom on. Defendant then ordered one

woman and then the other in the back seat with him and forced them each to perform multiple

sex acts. After defendant eventually ejaculated into the condom, he permitted the victims to

put their clothes back on and directed them to exit the car and stand behind the dumpster.

L.B.E. could see defendant moving around the car like he was “cleaning up.” After defendant

left, the victims called 911. The victims were transported to the hospital where sexual assault

kits were performed. Both victims identified defendant pretrial from a photo array.

¶6 In addition, a swab of the empty condom wrapper revealed a DNA mixture of at least

three people that was not suitable for comparison at the time of the offense. However, prior to

trial, the State used a newer method called STRmix DNA analysis. A DNA analyst testified

that, while this method does not provide a “match,” it does provide a likelihood ratio of a

person being a contributor. The analyst testified: “The DNA found from the condom wrapper

is approximately 110,000 times more likely if it originated from [defendant] and two unknown

unrelated individuals than if it originated from three unknown unrelated individuals.” He

concluded: “This analysis supplied strong support for the proposition that [defendant] is a

contributor to the DNA file identified from [the] condom wrapper.” No challenge is raised to

the DNA evidence on appeal.

¶7 After listening to the evidence, closing arguments and instructions, the jury found

defendant guilty. The trial court denied defendant’s posttrial motion for a new trial and

sentenced him to a total of 96 years. After his motion to reconsider sentence was denied,

defendant filed a notice of appeal, and this appeal followed.

¶8 ANALYSIS

3 No. 1-23-2494

¶9 I. Denial of Substitute Counsel

¶ 10 Defendant argues that the trial court abused its discretion in denying his motion for a

continuance to substitute new counsel on the eve of trial. Both parties cite in support People v.

Tucker, 382 Ill. App. 3d 916, 920 (2008). In Tucker, this court held: “The right to counsel of

choice, while fundamental, may be limited in some cases.” Tucker, 382 Ill. App. 3d at 920. “It

is within the trial court’s discretion to determine whether the defendant’s right to selection of

counsel unduly interferes with the orderly process of judicial administration.” Tucker, 382 Ill.

App. 3d at 920.

¶ 11 “Factors to be considered include: [(1)] whether defendant articulates an acceptable

reason for desiring new counsel; [(2)] whether the defendant has continuously been in custody;

[(3)] whether he has informed the trial court of his efforts to obtain counsel; [(4)] whether he

has cooperated with current counsel; and [(5)] the length of time defendant has been

represented by current counsel.” Tucker, 382 Ill. App. 3d at 920; People v. Adams, 2016 IL

App (1st) 141135, ¶ 13 (citing the five Tucker factors with approval). Further, new counsel

must be ready, willing, and able to appear on defendant’s behalf. Tucker, 382 Ill. App. 3d at

920. In Tucker, 382 Ill. App. 3d at 923, we reversed and remanded due to “the trial court’s

failure to inquire more thoroughly into defendant’s request” for a continuance to substitute

counsel.

¶ 12 We found that the trial court in Tucker failed to ask defendant (1) “why he wanted

another lawyer,” (2) “what he meant when he said that he [had] ‘hired’ another attorney,” and

(3) “whether he could afford” this new counsel. Tucker, 382 Ill. App. 3d at 923. In addition,

we found that the trial court had made “no finding that defendant’s attempt to hire a new lawyer

was a delaying tactic and not in good faith.” Tucker, 382 Ill. App. 3d at 923-24. “Given the

4 No. 1-23-2494

failure of the trial court to inquire” into the circumstances of defendant’s request, this court

had no choice but to reverse. Tucker, 382 Ill. App. 3d at 924; People v. Bingham, 364 Ill. App.

3d 642, 645 (2006) (the trial court abused its discretion in denying defendant’s motion to

substitute counsel, when it failed to conduct “an inquiry into the circumstances and the

purposes of the motion before making its ruling”).

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People v. Minnis, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-minnis-illappct-2026.