People v. Staake

2025 IL App (4th) 250034-U
CourtAppellate Court of Illinois
DecidedDecember 2, 2025
Docket4-25-0034
StatusUnpublished

This text of 2025 IL App (4th) 250034-U (People v. Staake) 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. Staake, 2025 IL App (4th) 250034-U (Ill. Ct. App. 2025).

Opinion

NOTICE 2025 IL App (4th) 250034-U This Order was filed under FILED Supreme Court Rule 23 and is December 2, 2025 not precedent except in the NO. 4-25-0034 Carla Bender limited circumstances allowed th 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. ) Sangamon County JARED M. STAAKE, ) No. 23CF237 Defendant-Appellant. ) ) Honorable ) Ryan M. Cadagin, ) Judge Presiding.

PRESIDING JUSTICE HARRIS delivered the judgment of the court. Justices Lannerd and DeArmond concurred in the judgment.

ORDER

¶1 Held: The appellate court affirmed, holding (1) the trial evidence was sufficient to prove defendant guilty beyond a reasonable doubt of armed violence and (2) any error in the trial court’s admission of cell phone records was harmless.

¶2 Defendant, Jared M. Staake, appeals his conviction for armed violence. Defendant

argues (1) the evidence at trial was insufficient to prove him guilty of the offense of armed

violence beyond a reasonable doubt and (2) the trial court erred by admitting cell phone records

as self-authenticating certified records of regularly conducted activity pursuant to Illinois Rule of

Evidence 902(11) (eff. Sept. 28, 2018). We affirm.

¶3 I. BACKGROUND

¶4 A grand jury charged defendant with armed violence (720 ILCS 5/33A-2(a) (West

2022)), aggravated battery with a firearm (id. § 12-3.05(e)(1)), attempted armed robbery (id.

§§ 8-4(a), 18-2(a)(2)), and unlawful possession of a weapon by a felon (UPWF) (id. § 24-1.1(a)). The charges stemmed from an incident in March 2023 during which defendant allegedly shot

Jeremy Evans. The trial court granted defendant’s motion to sever the UPWF charge, and the

matter proceeded to a three-day jury trial on the remaining three charges.

¶5 A. Cell Phone Records

¶6 On the last day of the trial, defense counsel stated that he believed the State would

seek to introduce cell phone records from AT&T for defendant and two other witnesses, Chelsie

Bounds and Ashley Savage. Counsel indicated he would object to the admission of the records

based on deficiencies in their certifications of authenticity and lack of notice. Specifically,

counsel stated that the certifications that were included in discovery were not compliant with

Rule 902(11) because the certifications did not indicate they were made under oath. Counsel

asserted that the State also failed to provide the requisite written notice of its intent to use the

records as self-authenticating documents under Rule 902(11). The trial court stated it would not

accept the certifications, but it allowed the State to attempt to obtain corrected certifications.

¶7 Later that day, the State submitted new certifications from AT&T. The three

certifications were identical to one another except for their “Matter ID” numbers. They were

notarized and stated that the record custodian making the certification had been “duly sworn.”

The State also submitted written notices of its intent to use the cell phone records of defendant,

Bounds, and Savage.

¶8 Defense counsel objected to the new certifications, stating they failed to comply

with Rule 902(11) because they did not state that they were made “under oath” or that they were

subject to the penalty of perjury. Counsel also argued that the notices of intent were untimely.

¶9 The trial court ruled that the records were admissible. The court found that the

certifications complied with Rule 902(11) because they were sworn before a notary, which

-2- established the statements contained in them were made under oath. The court agreed with

defense counsel that the notices of intent were untimely, but it found that excluding the records

on that basis would be elevating form over substance and that defense counsel was not caught off

guard by the State’s attempt to have the records admitted.

¶ 10 B. Trial Evidence

¶ 11 At the trial, Evans testified that he and Bounds had “an on-and-off relationship”

for several years. Bounds reached out to Evans on the day of the incident, and they made plans

for Bounds to come to his residence and “take care of [him]” because she knew he was sad about

a friend’s recent death. Evans believed they would have sexual relations.

¶ 12 Evans testified that, on the night of the incident, Bounds drove to his residence in

a white van and asked for gas money, saying she had to work in the morning. Evans gave her

money to buy gas and drinks. She left for approximately 40 minutes. When she returned, she

parked in front of Evans’s neighbor’s house. Evans walked out to the van, opened the door, and

saw Bounds crying. Someone wearing a black mask then walked up behind Evans, asked him for

money, and shot him two times before he could respond. According to Evans, it sounded like the

shooter had a male voice. Evans stated: “By the time I got back on my feet, [the shooter] was

already running to the van. They took off.” Evans then ran into his house and saw that he was

bleeding. The police arrived and placed him in an ambulance. He was treated for his gunshot

wounds at a hospital.

¶ 13 A Ring doorbell video recording from Evans’s residence was admitted into

evidence and played for the jury. The recording showed Evans leaving his house and walking

over to a white van parked on the street near the house. It then showed an individual wearing

dark clothing, including a long-sleeved garment, walking toward the van. In his testimony, Evans

-3- identified this individual as the shooter.

¶ 14 Three people who lived near Evans testified that they heard gunshots or fireworks

on the night of the incident. They all reported seeing someone running afterwards, but they could

not describe the individual.

¶ 15 Bounds testified that criminal charges relating to Evans’s shooting were currently

pending against her. She stated the prosecutor had not promised her anything in exchange for her

testimony. Bounds testified that, at the time of the incident, she was married to defendant, but

they were not living together. She stated she understood that because she was married to

defendant when the incident occurred, she was not allowed to testify about certain things he said

to her.

¶ 16 Bounds stated that, on the day of the incident, defendant picked her up in a white

van. They drove to Springfield, Illinois, where they stopped at a gas station and defendant’s

friend’s house. They later drove to defendant’s grandmother’s house in Beardstown, Illinois,

which is where defendant lived. They stopped in a rural area before they reached Beardstown

and shot at street signs with Bounds’s Glock 19 handgun. When they arrived at defendant’s

grandmother’s house, Bounds saw defendant loading a Glock 17 handgun. Both the Glock 17

and the Glock 19 belonged to Bounds. Defendant and Bounds left to pick up Savage in

Jacksonville, Illinois, because she needed a ride to Beardstown. When they left, defendant had

the Glock 17 either in the back of his pants or in a black box he brought with him. He was

wearing a black tank top and black pants.

¶ 17 Bounds testified that, after they picked up Savage, she drove to Springfield to

“come by [Evans’s] house.” She stated that, at the time of the incident, she had known Evans for

approximately three years.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Jackson v. Virginia
443 U.S. 307 (Supreme Court, 1979)
People v. Hall
743 N.E.2d 521 (Illinois Supreme Court, 2000)
People v. Collins
478 N.E.2d 267 (Illinois Supreme Court, 1985)
People v. Gray
2017 IL 120958 (Illinois Supreme Court, 2017)
People v. Fox
2022 IL App (4th) 210262 (Appellate Court of Illinois, 2022)

Cite This Page — Counsel Stack

Bluebook (online)
2025 IL App (4th) 250034-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-staake-illappct-2025.