People v. Murphy

2020 IL App (5th) 170363-U
CourtAppellate Court of Illinois
DecidedJune 12, 2020
Docket5-17-0363
StatusUnpublished

This text of 2020 IL App (5th) 170363-U (People v. Murphy) 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. Murphy, 2020 IL App (5th) 170363-U (Ill. Ct. App. 2020).

Opinion

NOTICE 2020 IL App (5th) 170363-U NOTICE Decision filed 06/12/20. The This order was filed under text of this decision may be Supreme Court Rule 23 and NOS. 5-17-0363, 5-17-0364 cons. changed or corrected prior to may not be cited as precedent the filing of a Peti ion for by any party except in the Rehearing or the disposition of IN THE limited circumstances allowed the same. under Rule 23(e)(1).

APPELLATE COURT OF ILLINOIS

FIFTH DISTRICT ________________________________________________________________________

THE PEOPLE OF THE STATE OF ILLINOIS, ) Appeal from the ) Circuit Court of Plaintiff-Appellee, ) Jefferson County. ) v. ) Nos. 15-CF-361, 16-CF-197 ) ) STEVEN MURPHY, ) Honorable ) Jerry E. Crisel, Defendant-Appellant. ) Judge, presiding. ________________________________________________________________________

JUSTICE MOORE delivered the judgment of the court. Presiding Justice Welch and Justice Cates concurred in the judgment.

ORDER

¶1 Held: Because the trial judge did not err in denying the defendant’s motion for a directed verdict where the factual allegations underlying the motion did not dictate granting the motion, the defendant’s convictions and sentences are affirmed.

¶2 The defendant, Steven Murphy, brings this consolidated direct appeal following a

single trial by jury, on joined charges, in the circuit court of Jefferson County. For the

following reasons, we affirm.

1 ¶3 I. BACKGROUND

¶4 Although the defendant in this case was convicted, following his September 2016

jury trial, of first degree murder, aggravated arson, and residential arson (the latter of which

was merged, posttrial, with the aggravated arson conviction), the sole issue raised by the

defendant in this consolidated appeal relates to his conviction for aggravated arson. He

does not challenge his murder conviction and sentence. He also does not raise any issue

regarding the charging instrument. Accordingly, we discuss in detail only those facts

necessary to our disposition of the issue raised by the defendant, and, for purposes of

context only, provide as well a brief summary of other facts related to the defendant’s trial

and convictions.

¶5 On September 28, 2015, the defendant was indicted, in case number 15-CF-361, on

the charge of aggravated arson. The indictment alleged that “on or about June 28, 2015,”

the defendant “committed the offense of aggravated arson, in that, while committing an

arson, said defendant knowingly partially damaged a building of [the victim], being a

residence, *** knowing that [the victim] was present therein, in violation of 720 ILCS

5/20-1.1, a Class X felony.”

¶6 On May 19, 2016, the defendant was indicted, in case number 16-CF-197, on two

counts of first degree murder, related to the death of the victim in case number 15-CF-361.

¶7 On May 24, 2016, the defendant filed a motion for compulsory joinder of his

aggravated arson and residential arson case with his recently-filed murder case, contending

that joinder was compulsory because all the charges were based upon “the same act.” Again

utilizing his “same act” theory, the defendant that same day filed a motion to dismiss the 2 murder charges on speedy trial grounds because of the length of time between the filing of

the arson charges and the murder charges, during which the defendant was in custody. On

June 6, 2016, the State filed a combined memorandum of law in opposition to the motions

for compulsory joinder and dismissal, contending that the charges did not relate to the same

act, and providing a proffer of the facts the State believed it would be able to prove at trial

that showed that the charges did not relate to the same act. Following a hearing, the trial

judge took the defendant’s motions under advisement, and subsequently denied them. Of

relevance thereto for purposes of the arguments put forward by the defendant in this appeal,

we note that prior to trial and at trial, the State’s theory was, in essence, that it could prove

that the defendant met the victim at a small house party at the victim’s residence, returned

to that residence after the party ended and sexually assaulted, physically assaulted, and

strangled the victim, then returned to the residence a final time, approximately 9 to 10 hours

later, and set fire to the residence in an attempt to destroy evidence of his earlier acts. Prior

to trial, the trial judge granted the defendant’s subsequent motion for permissive joinder,

and a single trial was held on all three charges.

¶8 At trial, during the State’s presentation of its case, the State attempted to prove its

theory with, inter alia, the following: (1) testimony of witnesses, including the victim’s

adult daughter, who had been at the party, as well as a witness who saw the defendant in

the vicinity of the residence around the time the fire began, and another witness who could

not identify the defendant, but saw a man resembling the defendant in the vicinity of the

residence around the time the fire began; (2) testimony from law enforcement officers and

other officials involved in the investigation; (3) video footage—as well as still photographs 3 derived from that video footage—from the surveillance system of a gas station near the

victim’s residence, showing the defendant at the gas station shortly before the fire began;

and (4) documentary evidence from the home security system of the victim’s residence,

which indicated the times at which the front and back doors of the residence were opened,

at and around the times in question at trial, and which showed that approximately four to

five minutes passed between the defendant’s return to the residence at approximately 11:16

a.m. (approximately 9 to 10 hours after the State contended the physical and sexual assaults

occurred) and the fire alarm going off within the residence at approximately 11:20 a.m.

¶9 Of significance to the issue raised by the defendant on appeal, the State also

presented testimony, in support of the theory it believed it could prove, from the following

three witnesses: Dr. John Heidingsfelder, firefighter Ryan Clinton, and arson investigator

Bruce Dahlem. Their testimony is described in detail below.

¶ 10 With regard to Dr. Heidingsfelder, at the request of the State following its

preliminary questioning of him—and without objection from the defense—Dr.

Heidingsfelder was qualified by the trial judge as an expert witness in forensic pathology.

He testified that on June 29, 2015, he conducted the autopsy on the victim at a local funeral

home. In terms of the background knowledge he had been given before beginning the

autopsy—knowledge that he testified helped him interpret the autopsy findings in this

case—he testified that he was told the victim “was found more or less face-down on the

floor in the living room with burning to her body,” and that he “was told that there were

areas of burning in the residence that were separate—away from this spot and that arson

was suspected and accelerants were suspected in the cause of this fire.” 4 ¶ 11 Dr. Heidingsfelder testified that during his external examination of the victim’s

body during the autopsy, he observed that the victim had extensive third degree burns to

her skin, including some charring of the skin, but that there were also still some pink areas

of skin. He testified that he believed the pink areas were where the victim “had contact

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Related

People v. Thomas
561 N.E.2d 57 (Illinois Supreme Court, 1990)
People v. Hancock
2014 IL App (4th) 131069 (Appellate Court of Illinois, 2014)
Perfetti v. Marion County, Illinois
2013 IL App (5th) 110489 (Appellate Court of Illinois, 2013)

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2020 IL App (5th) 170363-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-murphy-illappct-2020.