People v. Steffens

2025 IL App (5th) 230422-U
CourtAppellate Court of Illinois
DecidedMarch 6, 2025
Docket5-23-0422
StatusUnpublished

This text of 2025 IL App (5th) 230422-U (People v. Steffens) 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. Steffens, 2025 IL App (5th) 230422-U (Ill. Ct. App. 2025).

Opinion

NOTICE 2025 IL App (5th) 230422-U NOTICE Decision filed 03/06/25. The This order was filed under text of this decision may be NO. 5-23-0422 Supreme Court Rule 23 and is changed or corrected prior to the filing of a Petition for not precedent except in the

Rehearing or the disposition of IN THE limited circumstances allowed the same. under Rule 23(e)(1). APPELLATE COURT OF ILLINOIS

FIFTH DISTRICT ______________________________________________________________________________

THE PEOPLE OF THE STATE OF ILLINOIS, ) Appeal from the ) Circuit Court of Plaintiff-Appellee, ) Coles County. ) v. ) No. 05-CF-137 ) BOBBY G. STEFFENS, ) Honorable ) Mitchell K. Shick, Defendant-Appellant. ) Judge, presiding. ______________________________________________________________________________

JUSTICE BARBERIS delivered the judgment of the court. Justices Moore and Sholar concurred in the judgment.

ORDER

¶1 Held: We affirm defendant’s conviction and sentence on the offenses of predatory criminal sexual assault of a child, where the State’s errors did not amount to first- prong plain error, and defense counsel did not render ineffective assistance of counsel.

¶2 Following a jury trial in the circuit court of Coles County, defendant, Bobby G. Steffens,

was convicted of six counts of predatory criminal sexual assault of a child (720 ILCS 5/12-

14.1(a)(1) (West 2004)) and sentenced to mandatory natural life in prison. Defendant appeals,

arguing that the State improperly elicited the opinions of witnesses regarding the credibility of the

minor children, J.P. and C.V.; the State improperly commented on J.P. and C.V.’s credibility

during closing argument; and trial counsel rendered ineffective assistance of counsel by failing to

1 object to the State’s errors. Alternatively, defendant requests this court consider these errors under

the plain-error doctrine. For the following reasons, we affirm.

¶3 I. Background

¶4 We limit our recitation to those facts relevant to our disposition of this appeal. We will

recite additional facts in the analysis section as needed to address defendant’s specific arguments.

¶5 On March 18, 2005, the State charged defendant with three counts of predatory criminal

sexual assault of a child (id.), all Class X felonies, alleging that, from approximately October 2004

through March 2005, defendant, an individual 17 years of age or older, committed an act of sexual

penetration with J.P., his stepdaughter and an individual under 13 years of age, when defendant

placed his finger in J.P.’s vagina (count I), placed his mouth on J.P.’s vagina (count II), and placed

his penis on J.P.’s vagina (count III). The State subsequently charged defendant on May 6, 2005,

with three counts of predatory criminal sexual assault of a child (id.), all Class X felonies, alleging

that, from approximately October 2004 through March 2005, defendant committed an act of sexual

penetration with C.V., his stepdaughter and an individual under 13 years of age, when defendant

placed his finger in C.V.’s vagina (count IV), placed his penis in C.V.’s mouth (count V), and

placed his penis on C.V.’s vagina (count VI).

¶6 On September 2, 2005, the trial court held a hearing on the State’s motion to admit hearsay

evidence, pursuant to section 115-10 of the Code of Criminal Procedure of 1963 (Code) (725 ILCS

5/115-10(b) (West 2004)), 1 of J.P. and C.V.’s out-of-court statements made to Betty Christine

1 Section 115-10(b) of the Code provides that certain evidence shall be admitted as an exception to the hearsay rule under the following circumstances: “(1) The court finds in a hearing conducted outside the presence of the jury that the time, content, and circumstances of the statement provide sufficient safeguards of reliability; and (2) The child *** either: (A) testifies at the proceeding; or (B) is unavailable as a witness and there is corroborative evidence of the act which is the subject of the statement[.]” 2 Best, Detective Jason Taylor, Brenda Steffens, and Noelle Cope. The following evidence was

adduced.

¶7 A. Betty Christine Best

¶8 The State called Betty Christine Best, a school social worker at C.V.’s elementary school,

who testified to the following. Ms. Best spoke individually with C.V. after C.V. asked a female

classmate if C.V. could live with her family. During the interview, C.V. admitted that she wanted

to live with her female classmate because defendant, her dad, spanked her and her siblings with a

paddle and put them to bed early. C.V. also reported that defendant “like[d] to pat [her] kitty cat.”

C.V. then placed her hands near her pelvic area to show Ms. Best the location of her “kitty cat.”

Upon further inquiry, C.V. said that defendant “liked to rub it[,] and tr[ied] to put his fingers up

inside of her.” C.V. stated that her mother did not know about defendant’s touching. Defendant

touched J.P. in front of C.V., but C.V. did not know if defendant touched her younger brother, J.V.

Ms. Best did not believe that someone coached C.V. prior to the interview. Rather, C.V. used her

own words and terminology when explaining how defendant touched her. Ms. Best specified that

C.V. was in a “cross categorical program” for children with severe learning disabilities or mild

mental impairment. Despite C.V.’s disability, Ms. Best believed that C.V. adequately verbalized

her experience and did not embellish her story. Following Ms. Best’s testimony, the trial court

determined that C.V.’s statements to Ms. Best provided sufficient safeguards of reliability to admit

C.V.’s statements pursuant to section 115-10 of the Code.

¶9 B. Detective Jason Taylor

¶ 10 Detective Jason Taylor, a lieutenant with the Mattoon Police Department, testified that he

interviewed C.V. on March 15, 2005, regarding a possible criminal sexual assault. Detective

Taylor testified that, due to C.V.’s “developmental[ ] disab[ility],” he did not tape C.V.’s interview

3 because he found it hard to communicate with her. Detective Taylor explained that C.V. sometimes

provided him three answers to the same question. Based on what C.V. shared with him, he stated

that he “wasn’t totally convinced that an offense had taken place.” Detective Taylor detailed that

C.V. reported that defendant placed his finger in her “kitty cat” at night in her bedroom on 10 or

11 occasions. C.V. pointed to “the area between her legs” when Detective Taylor inquired about

the location of her “kitty cat.” C.V. stated that defendant came into her bedroom when her mother

was at the store or in another room playing a video game. According to C.V., defendant placed his

penis in her vagina on occasion. C.V. later stated that defendant “had not placed his penis into her

vagina on occasion.” C.V. indicated that defendant “ ‘gets his private out and plays with it a little

bit and then humps us.’ ” Upon further inquiry, C.V. stated that defendant “put his penis into her

vagina.” Detective Taylor shared that C.V. “was all over the roadway in her statement.” C.V.

initially stated that defendant started touching her in kindergarten. Next, she shared that defendant

touched her between kindergarten and March 2005, and then also stated that defendant touched

her between kindergarten and prior to 2005. C.V. could not pin down a particular time when the

offenses took place. Detective Taylor did not believe that someone coached C.V. or rehearsed with

her prior to the interview.

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2025 IL App (5th) 230422-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-steffens-illappct-2025.