People v. Sheley

2014 IL App (3d) 120012, 16 N.E.3d 857
CourtAppellate Court of Illinois
DecidedAugust 13, 2014
Docket3-12-0012
StatusUnpublished
Cited by1 cases

This text of 2014 IL App (3d) 120012 (People v. Sheley) 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. Sheley, 2014 IL App (3d) 120012, 16 N.E.3d 857 (Ill. Ct. App. 2014).

Opinion

2014 IL App (3d) 120012

Opinion filed August 13, 2014 ______________________________________________________________________________

IN THE

APPELLATE COURT OF ILLINOIS

THIRD DISTRICT

A.D., 2014

THE PEOPLE OF THE STATE ) Appeal from the Circuit Court OF ILLINOIS, ) of the 9th Judicial Circuit ) Knox County, Illinois Plaintiff-Appellee, ) ) Appeal No. 3-12-0012 ) Circuit No. 08-CF-338 v. ) ) NICHOLAS T. SHELEY, ) Honorable ) James B. Stewart Defendant-Appellant. ) Judge, Presiding. ______________________________________________________________________________

JUSTICE O’BRIEN delivered the judgment of the court, with opinion. Justices Carter and Holdridge concurred in the judgment and opinion. _____________________________________________________________________________

OPINION

¶1 Defendant Nicholas Sheley was convicted by a jury of first degree murder,

aggravated vehicular kidnapping, and possession of a stolen motor vehicle, and sentenced

to terms of imprisonment of natural life, 30 years and 7 years, respectively. He appeals

his conviction, arguing that he was denied a fair trial by an impartial jury because of

pretrial publicity. We affirm.

¶2 FACTS

¶3 In July 2008, defendant Nicholas Sheley was charged with numerous offenses,

including first degree murder, aggravated vehicular hijacking, and possession of a stolen motor vehicle. 720 ILCS 5/9-1(a)(2), 18-4(a)(1), 16-1(a)(1)(A) (West 2008). The

charges arose from a June 2008 incident in which Sheley was alleged to have beaten to

death Ronald Randall, a Galesburg resident, stolen Randall’s truck, and dumped

Randall's body. The Galesburg incident was part of a string of offenses allegedly

committed by Sheley over a several-day span in late June through early July 2008. The

allegations included that Sheley murdered a man in Whiteside County on June 23 and

stole his car; stole and burglarized other vehicles in Whiteside, Lee, and Rock Island

Counties, and stole a company vehicle that he drove to Galesburg, where he committed

the instant offenses on June 28. Sheley is further alleged to have then returned to

Whiteside County where he murdered four people, including a two-year-old child, and

then drove in Randall’s truck to Festus, Missouri, where he killed two more people.

Sheley was ultimately arrested on July 1, in Granite City, Illinois.

¶4 Extensive publicity followed the alleged crime spree and continued after Sheley’s

arrest on July 1, and local media covered the court proceedings throughout the pendency

of the case. The record includes 389 articles and news report transcripts, the majority of

which mention the crimes Sheley was alleged to have committed outside of Knox

County. Throughout the pretrial proceedings, the press covered Sheley's disagreements

with his lawyers, his decision to proceed pro se and his eventual return to representation

by counsel, and pretrial incidents in the county jail, where Sheley assaulted other

prisoners and jail staff. Media coverage also included abolishment of the death penalty in

Illinois and its effects on the Sheley trial, as well as coverage about unrelated crimes

committed by Sheley's brother. In September 2008, the trial court issued an order

prohibiting extra-judicial statements after Sheley held a press conference at the county

jail.

-2- ¶5 In March 2009, Sheley moved for a change of venue, arguing that the jury pool

had been tainted by the extensive media coverage. Sheley filed a supplemental motion to

change venue in June 2009, identifying specific instances of prejudicial information in

the media reports. He argued that the pervasive media coverage exposed the jury pool to

inaccurate, inflammatory, and sensationalized information, which was sympathetic to the

victim’s family, and that a demonstrative bias existed. Included with the supplemental

motion were the results of a public opinion survey commissioned by the defense. The

survey indicated that as of June 2, 2009, the majority of people who responded to the

survey and had heard at least some information about the case believed Sheley was

guilty. Specifically, of the 850 people who responded, 76% recalled the case; 71% of

those had at least some knowledge of it; 69% had learned about the case from the media

and community discussion; 68% had an opinion about Sheley’s guilt, with 87% believing

him to probably be guilty; and 65% indicated they could be impartial as a juror. At the

end of the poll, participants were provided the opportunity to leave a comment. The

comments reflected that participants viewed Sheley as guilty, people were following the

case, and the community was discussing it.

¶6 Sheley filed a second supplemental motion for change of venue in July 2009,

arguing that the media continued to report facts that would be inadmissible at trial,

including information about the other murders he was alleged to have committed. In

response to the change of venue motion, the State argued that the opinion poll also

revealed that 205 people had no knowledge, which changed the poll results. Per the

State's calculations, only 41% of potential jurors indicated they could not be impartial.

On October 28, 2009, defense counsel filed an affidavit in support of the motion to

change venue, attesting that there continued to be extensive media coverage of the case,

-3- including 173 articles and broadcast reports. The affidavit presented the results of a

second public opinion poll of 3,619 Knox County voters, with 997 people answering the

survey questions to some degree. The results of the poll indicated that as of October 8,

2009: 79% had knowledge of the case, with 82% of that number admitting that they

knew at least some details; 52% were aware of information from the media and 44%

from the media and discussion in the community; 86% of the responders believed Sheley

guilty and only 1% believed him innocent; and 63% stated it would be difficult to be

impartial. Statements left in the comments section of the survey indicated the

commenters had an extremely negative opinion about Sheley.

¶7 A hearing took place on Sheley’s motion for a change of venue on November 6,

2009. The parties stipulated to exhibits of the media coverage of the case and the exhibits

were entered into evidence. Following arguments of the parties, the trial court denied the

motion as premature, finding that the only way to determine whether it was possible to

seat an impartial jury was to attempt voir dire. The trial court distinguished the answers

given by Knox County residents to the questions in the public opinion poll from their

responsibilities as jurors, noting that as jurors, they are instructed on their role as well as

the law. The trial court also expressed that Knox County had an interest in the

proceedings and that the cost to transfer the proceedings elsewhere would be prohibitive.

The trial court noted that a jury was recently seated in one day for Sheley’s trial for

aggravated battery based on incidents at the county jail, which suggested an impartial

jury pool was available.

¶8 In March 2010, Sheley filed a second motion in limine to exclude evidence of the

murders in Whiteside County and Missouri. The State filed an offer of proof, titled

“Motion in limine to Admit Course of Conduct Evidence,” to establish that the other

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People v. Sheley
2014 IL App (3d) 120012 (Appellate Court of Illinois, 2014)

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2014 IL App (3d) 120012, 16 N.E.3d 857, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-sheley-illappct-2014.