People v. Pruitte

2024 IL App (4th) 240013-U
CourtAppellate Court of Illinois
DecidedDecember 10, 2024
Docket4-24-0013
StatusUnpublished
Cited by7 cases

This text of 2024 IL App (4th) 240013-U (People v. Pruitte) 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. Pruitte, 2024 IL App (4th) 240013-U (Ill. Ct. App. 2024).

Opinion

2024 IL App (4th) 240013-U NOTICE FILED This Order was filed under December 10, 2024 Supreme Court Rule 23 and is NO. 4-24-0013 Carla Bender not precedent except in the 4th District Appellate limited circumstances allowed IN THE APPELLATE COURT Court, IL under Rule 23(e)(1). OF ILLINOIS

FOURTH DISTRICT

THE PEOPLE OF THE STATE OF ILLINOIS, ) Appeal from the Plaintiff-Appellee, ) Circuit Court of v. ) McLean County DEAMONTAE D. PRUITTE, ) No. 21CF979 Defendant-Appellant. ) ) Honorable ) William A. Yoder, ) Judge Presiding.

JUSTICE VANCIL delivered the judgment of the court. Justices Steigmann and Lannerd concurred in the judgment.

ORDER ¶1 Held: The appellate court affirmed defendant’s first conviction for unlawful possession of a weapon by a felon (720 ILCS 5/24-1.1(a) (West 2020)), finding the evidence was sufficient to sustain a conviction and the unlawful use of a weapon statute did not violate the second amendment of the United States Constitution (U.S. Const., amend. II), but the court vacated defendant’s second conviction for unlawful possession of a weapon under the one-act, one-crime rule, vacated his 2011 conviction for aggravated unlawful use of a weapon (720 ILCS 5/24-1.6(a)(1), (a)(3)(A) (West 2010)) pursuant to People v. Aguilar, 2013 IL 112116, ¶¶ 20-22, and remanded for resentencing.

¶2 After a jury trial, defendant, Deamontae D. Pruitte, was found guilty of four counts

of unlawful possession of a weapon by a felon (UPWF), a Class 2 felony (720 ILCS 5/24-1.1(a)

(West 2020)). The trial court merged count III into count I and merged count IV into count II. It

sentenced defendant to a total of 14 years’ imprisonment on the remaining two counts.

¶3 Defendant appeals, arguing (1) the evidence was insufficient to sustain his

convictions, (2) the Illinois statute prohibiting UPWF is unconstitutional under the second amendment of the United States Constitution (U.S. Const., amend. II), (3) his convictions for two

separate counts violate the one-act, one-crime rule, (4) the trial court subjected him to an improper

double enhancement at sentencing, (5) the court improperly relied on a void ab initio conviction

for aggravated unlawful use of a weapon (AUUW) to increase his sentence, and (6) the court

otherwise abused its discretion at sentencing by imposing a sentence that was manifestly

disproportionate to the nature of the offense.

¶4 We vacate defendant’s conviction for count II, affirm his conviction for count I,

and remand for resentencing.

¶5 I. BACKGROUND

¶6 On September 22, 2021, the State indicted defendant on four counts of UPWF. The

indictment alleged that “on or about the 21st day of August, 2021,” defendant “knowingly

possessed a [.]380 caliber pistol firearm on or about his person.” Count I alleged defendant had

previously been convicted of robbery, a felony, in Will County case No. 17-CF-44, and he was on

parole or mandatory supervised release (MSR) at the time he possessed the pistol. Count II alleged

defendant had previously been convicted of robbery in Will County case No. 17-CF-44. Count III

alleged defendant had previously been convicted AUUW in Will County case No. 15-CF-462.

Finally, count IV alleged defendant had previously been convicted of AUUW in Will County case

No. 11-CF-1956.

¶7 Defendant pleaded not guilty, and his jury trial took place in May 2023. Brishia

Adams testified she was defendant’s ex-fiancée, and he was the father of her two-year-old

daughter. In 2021, she lived with him, their daughter, and her son. On August 21, 2021, police

officers came to her apartment twice, and she showed them a video on Snapchat. She testified

Snapchat is a social media application for uploading pictures and sending messages. She further

-2- testified she had created a Snapchat account in defendant’s name, she knew the password, and the

account was on her device. On the day of defendant’s arrest, she told police the account belonged

to defendant. At trial, she testified that this was untrue and that defendant had no access to the

account.

¶8 Adams testified she allowed the officer to record the Snapchat video, and the

recording was admitted into evidence. The recording shows a phone, and the phone is playing a

video of defendant holding two handguns, one black and one pink. Adams testified she uploaded

the video to the Snapchat account in defendant’s name on August 21, 2021, but the video was

recorded in 2019. She testified defendant had recorded the video, but she uploaded it. She admitted

she did not tell the officer this in August 2021. Instead, she told the officer it was a recent video.

¶9 Adams further testified she told the officer about text messages with defendant. She

had defendant saved as a contact in her phone under the name “Deamontae.” She allowed officers

to take pictures of text messages she showed them. The State admitted pictures of those messages

into evidence. In the messages, defendant sent Adams a photograph of two handguns, one black

and one pink, and magazines sitting on a cushion, and he told her the price of the two guns.

¶ 10 At trial, Adams claimed she had owned two cell phones, and she had given one to

defendant, although she denied he used it “regularly.” Adams provided two possible e-mail

addresses associated with the iPhone account. She did not remember the phone number for the

phone that defendant was using. She thought perhaps there was no phone number, only an e-mail

account connected to iCloud. Adams testified the phone in defendant’s possession was connected

to her iCloud account, and the photograph of the guns was taken from that account. At trial, she

claimed she took the photograph of the two guns, but she acknowledged that she did not tell police

this in August 2021. She testified she needed the picture of the guns on the cushion from her iCloud

-3- account, and defendant sent it to her. She testified she wanted to purchase a gun, she had a valid

firearm owners identification card, and defendant was simply telling her the price. She further

testified she and defendant were communicating by voice memo in addition to the text messages,

and those voice memos were not reflected in the text message conversation.

¶ 11 Adams admitted to the jury that when she spoke to the police, she told the officers

defendant was trying to obtain the guns, not her. She explained that she had wanted defendant to

leave their shared apartment, and when the officers arrived the first time, they told her she could

not compel defendant to leave the apartment if he had not committed any crime. She testified she

was “very intoxicated” and “upset.” The prosecutor asked whether she remembered telling officers

defendant wanted a gun because a few weeks earlier, his brother had shot at him and he had talked

about how “retribution is inevitable.” She admitted she told the officers that.

¶ 12 Adams denied talking to defendant about the court case, and she denied receiving

a message from defendant saying, “I went to court today. They said my whole trial is around your

testimony, the cellular device belonging to you, and the iCloud can upload an old [photograph]

because it is attached to your phone. Explain all that information.” Although she denied receiving

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Cite This Page — Counsel Stack

Bluebook (online)
2024 IL App (4th) 240013-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-pruitte-illappct-2024.