People v. Purdle

2021 IL App (3d) 190126-U
CourtAppellate Court of Illinois
DecidedOctober 21, 2021
Docket3-19-0126
StatusUnpublished

This text of 2021 IL App (3d) 190126-U (People v. Purdle) 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. Purdle, 2021 IL App (3d) 190126-U (Ill. Ct. App. 2021).

Opinion

NOTICE: This order was filed under Supreme Court Rule 23 and is not precedent except in the limited circumstances allowed under Rule 23(e)(1).

2021 IL App (3d) 190126-U

Order filed October 21, 2021 ____________________________________________________________________________

IN THE

APPELLATE COURT OF ILLINOIS

THIRD DISTRICT

THE PEOPLE OF THE STATE OF ) Appeal from the Circuit Court ILLINOIS, ) of the 10th Judicial Circuit, ) Peoria County, Illinois, Plaintiff-Appellee, ) ) Appeal No. 3-19-0126 v. ) Circuit No. 18-CF-462 ) KENCEY RICO PURDLE, ) Honorable ) Katherine S. Gorman, Defendant-Appellant. ) Judge, Presiding. ____________________________________________________________________________

PRESIDING JUSTICE McDADE delivered the judgment of the court. Justices Holdridge and Lytton concurred in the judgment. ____________________________________________________________________________

ORDER

¶1 Held: The circuit court did not abuse its discretion in determining there was manifest necessity for declaring a mistrial. Defendant’s conviction for criminal sexual assault violates the one-act, one-crime doctrine.

¶2 Defendant, Kencey Rico Purdle, appeals his convictions for home invasion and criminal

sexual assault. Initially, defendant raised two arguments on appeal: (1) the Peoria County circuit

court abused its discretion in declaring a mistrial during his first trial, and (2) the court used an

improper extended-term sentencing range in imposing his sentence for criminal sexual assault. Subsequently, we ordered the parties to provide supplemental briefing on whether defendant’s

conviction for criminal sexual assault violates the one-act, one-crime doctrine. Upon review of

the original and supplemental briefs, we affirm in part and vacate in part.

¶3 I. BACKGROUND

¶4 Defendant was charged with home invasion (720 ILCS 5/19-6(a)(6) (West 2018)),

criminal sexual assault (id. § 11-1.20(a)(1)), and residential burglary (id. § 19-3(a)). The charges

stemmed from a single incident in which defendant allegedly entered the residence of the victim

and sexually assaulted her.

¶5 A jury trial was held. After the jury was selected, defendant moved for a mistrial based

on the racial composition of the jury pool. The court denied the motion.

¶6 The State called the victim as its first witness. The victim testified that, on the night of

the incident, she was sleeping in her residence. Her nine-year-old son and six-year-old daughter

were also in the residence. The victim woke at 4 a.m. and saw a man standing in her bedroom.

He was exposing himself. She had seen the man before. He had exposed himself to her outside

her residence on a prior occasion. She identified defendant in court as the man who had been in

her bedroom. Defendant told her that if she did anything “stupid,” he would “do it to [her]

daughter.” He then placed his penis in her mouth and vagina.

¶7 The victim testified that she identified defendant in a photographic lineup shortly after

the incident. At the time, she said that she was 90% sure that he was the man who had assaulted

her, but she would need to see him again. On cross-examination, defense counsel asked the

victim when she saw defendant again before the trial. The victim replied:

“My case manager at the apartment looked up his other felonies since his name

was on there, and it showed a picture of him on the computer, a large screen. ***

2 She didn’t look up what he did this time. She looked up what he did prior times,

and she showed me a picture of him.”

The victim saw this photograph approximately eight weeks after she was assaulted. Defense

counsel asked the victim if she knew which photograph she was looking at. She replied, “His

other felonies.” The victim did not know when the photograph was taken. Defense counsel asked

the victim where she obtained this photograph. The victim replied, “I don’t know, because I’m

not the one that pulled it up. It was something to do with his past felonies.” Defense counsel

again asked the victim where she obtained the photograph. The victim replied, “It was his name

from a felony background and had his picture up.” She then said that the photograph came from

police records.

¶8 After defense counsel finished his questioning, the court excused the jurors from the

courtroom and asked the parties if they had any motions they wanted to make. The State said that

the victim had never mentioned knowing about defendant’s past felonies before her trial

testimony.

¶9 The court stated that it believed the victim had mentioned defendant’s prior felonies

approximately five times and that two of the times were invited by defense counsel’s questions.

The court said that it did not know if these were felony convictions or felony arrests for which

defendant was later acquitted. The court stated: “Now, the fear here is always that if the jury will

disregard the evidence and say the defendant’s got a bunch of prior felony convictions, he’s a

bad person, so we’ll convict him because of that, and I don’t know how valid that fear is.” The

court noted that declaring a mistrial was one option, but it had not yet decided whether it would

do so.

3 ¶ 10 The court said that it “let it go” the first time the victim mentioned defendant’s prior

felonies, but she mentioned it several more times. The court stated that on at least two of these

occasions, defense counsel should have known that his questions were going to cause the victim

to talk about defendant’s past felonies. The court said that the defense “must not think it’s so bad

since they went and asked her to say it two more times.” The court stated that it did not know if

defense counsel’s questions could amount to a waiver of the error. The court asked if either party

wanted a mistrial or if defense counsel wanted to speak to defendant alone. Defense counsel said

that he wanted time to speak with defendant, and a recess was held.

¶ 11 When the parties returned to the courtroom, the court recounted what had happened

during the victim’s testimony. The court said that it made a “[j]udgment call” not to stop the

proceedings after the first time the victim mentioned defendant’s prior felonies. The court

believed that the jury might not notice. The court also believed that if it had stopped the

proceedings and excused the jury, it would have highlighted the victim’s testimony concerning

defendant’s prior felonies in the minds of the jurors. The court said that it did not know that the

victim would proceed to mention defendant’s felonies several more times. The court explained

that it stopped the proceedings after defense counsel had completed his cross-examination

because it seemed like a natural time to stop that would not raise the suspicions of the jurors.

¶ 12 The court asked defense counsel if he was requesting a mistrial. Defense counsel said he

had discussed the matter with defendant and that they would not be requesting a mistrial. The

State said it would not be requesting a mistrial either. The court asked to see the attorneys in

chambers.

¶ 13 When the parties returned to the courtroom, the court said that it was declaring a mistrial.

The court stated that it had discussed with the attorneys the possibility that defense counsel had

4 waived defendant’s right not to have the jury know about his felony convictions by repeatedly

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Bluebook (online)
2021 IL App (3d) 190126-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-purdle-illappct-2021.