People v. Sanders

2024 IL App (4th) 230805-U
Procedural entryThis page is a short order in People v. Sanders. Read the opinion of the Court — 2024 IL App (3d) 230504-U
Appellate Court of Illinois·Decided August 2, 2024·No. 4-23-0805·Unpublished

Opinion

2024 IL App (4th) 230805-U NOTICE FILED This Order was filed under August 2, 2024 Supreme Court Rule 23 and is NO. 4-23-0805 not precedent except in the Carla Bender th limited circumstances allowed 4 District Appellate under Rule 23(e)(1). IN THE APPELLATE COURT Court, IL

OF ILLINOIS

FOURTH DISTRICT

THE PEOPLE OF THE STATE OF ILLINOIS, ) Appeal from the Plaintiff-Appellee, ) Circuit Court of v. ) Rock Island County JERRY J. SANDERS, ) No. 20CF710 Defendant-Appellant. ) ) Honorable ) Frank R. Fuhr, ) Judge Presiding. ______________________________________________________________________________

JUSTICE HARRIS delivered the judgment of the court. Presiding Justice Cavanagh and Justice Knecht concurred in the judgment.

ORDER

¶1 Held: (1) The State’s evidence was sufficient to prove defendant guilty of first degree murder beyond a reasonable doubt.

(2) Defendant forfeited his claim that the trial court abused its discretion by admitting the victim’s hearsay statements under the excited utterance exception to the hearsay rule, and he failed to establish that the plain error doctrine should be applied to excuse his forfeiture.

¶2 Following a jury trial, defendant, Jerry J. Sanders, was found guilty of first degree

murder (720 ILCS 5/9-1(a)(2) (West 2020)) and sentenced to 55 years in prison. He appeals,

arguing (1) the State failed to prove his guilt beyond a reasonable doubt because it relied primarily

on unreliable eyewitness identification testimony and grainy surveillance video and (2) the trial

court improperly admitted the victim’s hearsay statements under the excited utterance exception

to the hearsay rule. We affirm. ¶3 I. BACKGROUND

¶4 In September 2020, the State charged defendant with first degree murder (id.) in

connection with the shooting death of Jeremy Jackson, alleging defendant “shot at” Jeremy

“knowing such act created a strong probability of death or great bodily harm,” and that during the

offense, defendant “personally discharged a firearm that proximately caused [Jeremy’s] death.”

(Although the record reflects the State proceeded under subsection (a)(2) of the first degree murder

statute (id.), alleging defendant knew his acts created “a strong probability of death or great bodily

harm,” the charging instrument erroneously cited subsection (a)(1) of the statute (id. § 9-1(a)(1)),

which provides that a defendant “either intends to kill or do great bodily harm *** or knows that

[his] acts will cause death.”) The State’s theory of the case was that during the evening of August

29, 2020, and into the early morning hours of August 30, 2020, defendant and Jeremy socialized

with the same group of individuals at different locations in Rock Island County, Illinois. The group,

including defendant and Jeremy, ended the evening in the parking lot of the Warren Heights

Apartments (Warren Heights) in Silvis, Illinois. There, according to the State, defendant fired

multiple gunshots at a moving vehicle in which Jeremy was a back seat passenger, shooting Jeremy

in the back and causing his death.

¶5 Prior to trial, defendant filed a motion in limine, asking the trial court to bar witness

testimony that, shortly before the shooting, Jeremy made statements “about the presence of a gun.”

He argued the statements were hearsay and did not fall within any recognized hearsay exception.

¶6 In March 2022, defendant’s jury trial was conducted. Following jury selection, the

trial court heard arguments on defendant’s motion in limine. Defendant reiterated his claims,

asserting Jeremy made a statement prior to the shooting that “the guy in white had a gun,” which

should be excluded as hearsay. The State represented that several witnesses would testify that,

-2- prior to the shooting, Jeremy said, “that dude’s got a gun.” It argued the statement was admissible

either as an excited utterance or to show the effect of the statement on the listener because “[t]hey

all immediately decide[d] we are going to get out of here.” Defense counsel responded that

surveillance video in the case did not show people immediately leaving the scene but, instead,

getting out of their car to look around. A portion of the surveillance video was played for the court,

after which it “tentative[ly]” ruled that the statement was inadmissible. However, the court also

stated the matter could be readdressed prior to the start of trial the next day, asserting it intended

to “do a little research” and asking both parties “to see if they [could] find any law” to show that

it’s ruling was “wrong.”

¶7 The following day, the trial court stated that upon “further research,” it believed

Jeremy’s statement regarding a gun could qualify as an excited utterance, “depending on what

these witnesses say.” The State made an offer of proof with one of its witnesses, Juanlangeno

Jackson (Juan), who testified Jeremy was his uncle and the two spent time together with other

individuals on the night of the shooting. While at the Warren Heights parking lot, Jeremy left the

vehicle he had been riding in. When he returned, Juan heard Jeremy say, “ [‘]He got a gun.[’] ”

Juan and another person got out of the vehicle and “looked” before deciding to leave the parking

lot.

¶8 The trial court determined Jeremy’s statement to Juan met all of the requirements

for application of the excited utterance exception and that it was admissible. The court stated as

follows:

“Based on—actually, based on my review of the video yesterday during the motion

in limine and this person’s testimony, I do find that the statement, ‘He has a gun,’

meets all three of the requirements for an excited utterance. It’s sufficiently startling

-3- to produce a spontaneous statement, which it sounds like exactly what happened,

he walked back to them and told them, ‘He’s got a gun.’ There wasn’t any time to

make it up, and it’s relevant to the—and the statements [sic] relates to the

circumstances of the occurrence. So I’m going to admit it over the objection of

[defendant].”

The court indicated its ruling pertained only to Juan’s testimony, stating an offer of proof would

be required for each witness the State wished to testify about Jeremy’s out-of-court statement.

¶9 At trial, evidence showed that around 3:21 a.m. on August 30, 2020, police officers

responded to a Circle K gas station in East Moline, Illinois, after receiving a call about shots being

fired. At the scene, officers observed an injured person, later identified as Jeremy, inside a gray

Dodge Charger. He had a gunshot wound to his back and died as a result of his injury.

¶ 10 The State’s evidence showed that earlier the same night, a group of Jeremy’s friends

and relatives spent the evening “[d]rinking and going out.” Initially, they visited a bar called

Quarter Til Tap. Individuals present at the bar included Juan, Sharone Jackson, Shaniece Howell,

Jakarta Jackson, Keeley Brown, and Laprice Jackson, a bartender at Quarter Til Tap. Evidence

showed Juan, Sharone, Shaniece, and Jakarta arrived at the bar in a Dodge Charger driven by

Sharone. After leaving Quarter Til Tap, the group—Juan, Sharone, Shaniece, Jakarta, Keeley, and

Laprice—went to Jim’s Domino Lounge in East Moline, where they met up with Jeremy.

Thereafter, the group drove to Warren Heights in Silvas, where Laprice resided.

¶ 11 Juan testified he was drinking at Quarter Til Tap. He estimated he had seven shots

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People v. Sanders, 2024 IL App (4th) 230805-U (Ill. Ct. App. 2024).

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