People v. Patterson

2024 IL App (1st) 221619, 256 N.E.3d 1191
CourtAppellate Court of Illinois
DecidedDecember 27, 2024
Docket1-22-1619
StatusPublished
Cited by1 cases

This text of 2024 IL App (1st) 221619 (People v. Patterson) 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. Patterson, 2024 IL App (1st) 221619, 256 N.E.3d 1191 (Ill. Ct. App. 2024).

Opinion

2024 IL App (1st) 221619

No. 1-22-1619

Opinion filed December 27, 2024

FIFTH DIVISION

IN THE APPELLATE COURT OF ILLINOIS FIRST JUDICIAL DISTRICT

THE PEOPLE OF THE STATE OF ILLINOIS, ) Appeal from the ) Circuit Court of Plaintiff-Appellee, ) Cook County. ) v. ) No. 20118830901 ) CHARLES PATTERSON, ) Honorable ) Clarence L. Burch, Defendant-Appellant. ) Judge, presiding.

JUSTICE MITCHELL delivered the judgment of the court, with opinion. Presiding Justice Mikva and Justice Oden Johnson concurred in the judgment and opinion.

OPINION

¶1 Defendant Charles Patterson appeals his conviction for aggravated assault. He raises the

following issues on appeal: (1) did the circuit court abuse its discretion when it refused defendant’s

proposed self-defense jury instructions? (2) did the circuit court abuse its discretion when it refused

to provide substantive answers to the jury’s questions about the legality of defendant’s gun

possession? and (3) did the circuit court commit reversible error in failing to admonish defendant

as to his right to testify in his own defense? For the following reasons, we reverse defendant’s

conviction and remand his case for a new trial. No. 1-22-1619

¶2 I. BACKGROUND

¶3 On March 15, 2020, Tomas Alanis drove down Randolph Street in Chicago after

completing a food delivery. Alanis drove in the lane closest to the sidewalk when a taxi entered

his lane “without any caution.” The taxi was driven by defendant Charles Patterson, a 68-year-old

taxi driver. Because the taxi was two feet from Alanis’s vehicle when it entered the lane, Alanis

went into the center lane to avoid a collision. The taxi quickly entered the center lane in front of

Alanis, so Alanis changed lanes again. Alanis honked his vehicle’s horn but did not make any

gestures towards defendant.

¶4 Defendant and Alanis continued driving down the street until they reached a red light. At

this point, the vehicles were stationary, side by side, with Alanis’s vehicle in the center lane and

defendant’s taxi in the turn lane. Defendant’s vehicle’s windows were open. Alanis exited his car

and stood in front of it. He was approximately six feet away from defendant. Alanis was “upset”

and asked defendant, “Why did you try to hit me?” Alanis did not yell at or threaten defendant and

was not holding anything in his hands. Defendant pointed a handgun at Alanis from inside his car

and “said something to [Alanis] like ‘[m]ove or leave or I will shoot.’ ” This frightened Alanis and

he got back inside his car. Alanis followed defendant while calling 911 and told the police

defendant’s taxi number and that defendant had a gun. Defendant’s vehicle was later stopped by

the police and defendant was arrested.

¶5 Defendant was charged with aggravated assault for pointing a handgun at Tomas Alanis.

720 ILCS 5/12-2(c)(1) (West 2018). Defendant provided notice to the State that he would be

asserting the affirmative defense of self-defense at trial. 720 ILCS 5/7-1 (West 2020). At trial, the

State presented two witnesses. The first witness was Alanis, who testified through a Spanish

-2- No. 1-22-1619

translator about the encounter between himself and defendant, as recounted above. The second

witness was Officer Vasile Talos of the Chicago Police Department. Officer Talos testified that

during the arrest defendant admitted to having a firearm in his possession and that a weapon was

recovered at the scene by another police officer, although Officer Talos did not have firsthand

knowledge of whether or not a weapon was recovered. After Officer Talos concluded his

testimony, the State rested its case-in-chief.

¶6 Outside the presence of the jury, defense counsel requested that the jury be instructed with

the Illinois pattern jury instruction for use of force in defense of a person. Illinois Pattern Jury

Instructions, Criminal, No. 24-25.06 (4th ed. 2000). Defense counsel argued that “[t]he bar is very

low on what constitutes any evidence that self-defense is a proper instruction.” Counsel further

argued that Alanis’s testimony that he exited his car to confront defendant while they were both

stopped at the intersection because he was upset that defendant cut him off “more than clears the

bar of any evidence, a scintilla of evidence, *** that is required for a self-defense jury instruction.”

The circuit court denied defendant’s request for self-defense jury instructions, ruling that Alanis’s

testimony was insufficient evidence to support self-defense instructions. The circuit court also

denied defendant’s request that the jury be instructed that a non-initial aggressor has no duty to

retreat. See Illinois Pattern Jury Instructions, Criminal, No. 24-25.09X (4th ed. 2000).

¶7 Defendant called one witness, Officer Talos, who testified that one of his assisting officers

asked defendant whether he had a valid conceal and carry license, that defendant had “admitted to

it,” and that Officer Talos could not recall receiving any information that contradicted defendant’s

assertion. During closing arguments, defense counsel argued that Alanis’s testimony that he calmly

confronted defendant about his driving was not credible:

-3- No. 1-22-1619

“Then he says that he calmly got out to have that civil conversation with Mr.

Patterson. Now, I don’t know if anyone else has experience with road rage, but it sounds

like Mr. Alanis was the one with the road rage here.

You know I don’t know if anyone here has ever been unfortunate enough to have

somebody else get out of their car and confront them in the traffic but it’s a scary situation.

And it’s not something you do calmly.”

During its rebuttal, the State argued that self-defense was not applicable here:

“Imagine the scenario where you’re in a crowded room and someone bumps you

and you go, ‘hey, what did you do for that?’ And the person pulls out a gun. That’s not

right. That’s not self defense. That’s not anything but aggravated assault with a deadly

weapon.”

¶8 During the course of the jury’s deliberations, it sent the circuit court eight separate notes

containing a total of ten questions. Only the notes relevant to defendant’s arguments on appeal are

discussed here. The jury’s first note asked, “Is self defense a possible issue that can be considered?”

Defense counsel again asked that the jury receive self-defense instructions. The circuit court

refused again but told the jury that the answer to its question was “yes.” The circuit court concluded

that was the correct response because the jury “didn’t say a defense. They said an issue. So if they

want to consider that, you know that could be part of reasonable doubt.” After approximately an

hour, the jury sent its second note, which asked, “What is the next step if we can’t agree?” The

circuit court’s response was, “You have heard the evidence please continue in your deliberations.”

¶9 The jury’s fourth note asked three questions: (1) “Was the defendant allowed to be

armed?”; (2) “Did he have a permit to carry?”; and (3) “Was he allowed to carry while working as

-4- No. 1-22-1619

a cab driver?”. The circuit court did not address this note. The circuit court did not inform counsel

of the note and it provided no answers to the jury. The jury’s fifth note asked, “Was [defendant]

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2025 IL App (1st) 240888-U (Appellate Court of Illinois, 2025)

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Bluebook (online)
2024 IL App (1st) 221619, 256 N.E.3d 1191, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-patterson-illappct-2024.