People v. Rufus

2021 IL App (1st) 182048-U
CourtAppellate Court of Illinois
DecidedFebruary 24, 2021
Docket1-18-2048
StatusUnpublished

This text of 2021 IL App (1st) 182048-U (People v. Rufus) 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. Rufus, 2021 IL App (1st) 182048-U (Ill. Ct. App. 2021).

Opinion

2021 IL App (1st) 182048-U

THIRD DIVISION February 24, 2021

No. 1-18-2048

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).

IN THE APPELLATE COURT OF ILLINOIS FIRST JUDICIAL DISTRICT

THE PEOPLE OF THE STATE OF ILLINOIS, ) Appeal from the Circuit Court of ) Cook County. Plaintiff-Appellee, ) ) v. ) No. 10 CR 17762 ) GERALD RUFUS, ) ) Honorable William H. Hooks, Defendant-Appellant. ) Judge Presiding.

PRESIDING JUSTICE HOWSE delivered the judgment of the court. Justices McBride and Ellis concurred in the judgment.

ORDER

¶1 Held: The trial court did not err when it dismissed defendant’s postconviction petition alleging ineffective assistance of trial and appellate counsel because defendant was not prejudiced by his counsel’s representation.

¶2 Defendant Gerald Rufus was charged with and convicted of first-degree murder for

killing his girlfriend Theresa Russell. Defendant filed a postconviction petition alleging, among

other things, that his attorneys were constitutionally ineffective. On appeal, defendant argues that 1-18-2048

both his trial counsel and his appellate counsel were ineffective for failing to seek the

suppression of statements he made to police on the basis that the statements were obtained in

violation of Miranda v. Arizona, 384 U.S. 436 (1966). Defendant’s claim fails because he was

not subject to custodial interrogation when he made the statements to police and because he

cannot show prejudice. Finding no reversible error in the dismissal of defendant’s postconviction

petition, we affirm.

¶3 BACKGROUND

¶4 Theresa Russell was shot and killed on February 25, 2005. Chicago Police were called to

the scene. Officer Robert Shoup was one of the responding officers. When police arrived, they

saw Russell’s body on the floor of the apartment and defendant was straddling her, crying, while

he was calling for an ambulance. The officers observed that defendant had blood on his clothes

and was distressed. When Officer Shoup asked defendant what happened, defendant replied that

there was a drive-by shooting in front of the apartment, that Russell was shot, and that defendant

had to carry Russell from outside, up the stairs, and into the apartment. The officers attempted to

move defendant from his position on top of Russell’s body to preserve the crime scene, but

defendant did not want to move from atop Russell. Officer Shoup had to grab defendant and

convince him to move away from Russell’s body.

¶5 Officer Shoup led defendant away from the area where Russell’s body was located to the

back porch and asked defendant again what happened. This time, defendant stated that he and

Russell were outside on the back porch when a van drove through the alley. Defendant claimed

that Russell was struck by a gunshot fired from the van and defendant carried her inside from the

back porch.

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¶6 Officer Shoup sought clarification from defendant’s conflicting accounts and asked

defendant a third time what happened. This time, defendant stated that the shooters came up the

back porch stairs and fired into the apartment, striking Russell. The three questions Officer

Shoup asked defendant occurred within the first 15 minutes the police arrived at the scene. The

officers spoke with the other people present at the scene, which were defendant’s aunt and uncle

and two of his cousins. The officers did not recover a weapon or any shell casings. The officers

asked defendant to submit to a gunshot residue test, but defendant refused. The officers only

observed blood near Russell’s body, they did not locate any blood in the front or the back of the

apartment or on the stairs leading into the apartment. The officers searched the area around the

building and could not find any evidence that would have supported any of the accounts that

defendant had given. The officers arrested defendant and he was later charged with Russell’s

murder.

¶7 After defendant was arrested and taken to the station, a gunshot residue test was

administered. The test revealed no gunshot residue on defendant’s hands or his clothes. The

medical examiner that performed Russell’s autopsy determined that Russell had been shot from a

distance of less than six inches away. The bullet went through her left arm and into her chest

causing her death.

¶8 Before trial, defense counsel filed a motion to suppress the statements defendant made to

the officers. The original written motion focused primarily on an alleged violation of defendant’s

Fourth Amendment rights. Defendant argued that the officers did not have probable cause to

arrest defendant based upon their observations at the scene and, thus, the statements that

defendant made after an illegal seizure should be suppressed.

3 1-18-2048

¶9 At the hearing on the motion to suppress, principally in response to questions posed by

the trial judge, counsel argued that defendant’s statements should be suppressed because of an

alleged violation of defendant’s Fifth Amendment rights. Counsel argued that defendant should

have been read his Miranda rights when he was taken to the back porch and questioned by

Officer Shoup. Counsel argued that when police made a determination that defendant was a

suspect and began asking him questions about what happened, “at that point they should have

advised him of his rights and they did not.” Defense counsel further filed a post-hearing brief in

support of defendant’s motion to suppress the statements in which defendant argued that his

statements should be suppressed because defendant was under arrest once Officer Shoup grabbed

him to move him away from Russell’s body. Defendant argued that when Officer Shoup placed

his hands on defendant and moved him to another area of the house, defendant was seized and

his subsequent statements should be suppressed. The trial court denied the motion to suppress.

¶ 10 Defendant was tried by a jury. The jury found defendant guilty of first-degree murder.

The trial court sentenced defendant to 60 years in prison. Defendant appealed his conviction to

this court. On appeal, defendant argued that the trial court committed errors when conducting

voir dire. We affirmed defendant’s conviction and, in doing so, we noted that the evidence at

trial was not closely balanced. People v. Rufus, 2016 IL App (1st) 134008-U.

¶ 11 A year after we affirmed defendant’s conviction on appeal, defendant filed a

postconviction petition in the trial court. In his postconviction petition, which defendant filed pro

se, defendant argued, among other things, that his attorneys were constitutionally ineffective. In

support of his claim that he did not receive effective assistance of counsel, defendant alleged that

he made statements to Officer Shoup without being read his Miranda rights and, thus, his

4 1-18-2048

statements should have been suppressed. The trial court summarily dismissed defendant’s

postconviction petition. Defendant now appeals the dismissal of his postconviction petition.

¶ 12 ANALYSIS

¶ 13 The issue on appeal in this case is whether defendant raised an arguably meritorious

constitutional claim for ineffective assistance of counsel, such that he is entitled to proceed to the

second stage of postconviction review.

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Cite This Page — Counsel Stack

Bluebook (online)
2021 IL App (1st) 182048-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-rufus-illappct-2021.