People v. Thongjareon

2025 IL App (2d) 240344-U
CourtAppellate Court of Illinois
DecidedSeptember 22, 2025
Docket2-24-0344
StatusUnpublished

This text of 2025 IL App (2d) 240344-U (People v. Thongjareon) 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. Thongjareon, 2025 IL App (2d) 240344-U (Ill. Ct. App. 2025).

Opinion

2025 IL App (2d) 240344-U No. 2-24-0344 Order filed September 22, 2025

NOTICE: This order was filed under Supreme Court Rule 23(b) and is not precedent except in the limited circumstances allowed under Rule 23(e)(1). ______________________________________________________________________________

IN THE

APPELLATE COURT OF ILLINOIS

SECOND DISTRICT ______________________________________________________________________________

THE PEOPLE OF THE STATE ) Appeal from the Circuit Court OF ILLINOIS, ) of Kane County. ) Plaintiff-Appellee, ) ) v. ) No. 21-CF-1196 ) SUWIT THONGJAREON, ) Honorable ) C. Thomas Hull III, Defendant-Appellant. ) Judge, Presiding. ______________________________________________________________________________

JUSTICE SCHOSTOK delivered the judgment of the court. Presiding Justice Kennedy and Justice McLaren concurred in the judgment.

ORDER

¶1 Held: In defendant’s trial for aggravated criminal sexual abuse, the trial court did not err by admitting defendant’s prior conviction of unlawful restraint as impeachment evidence. Moreover, any error was harmless given the evidence of guilt and the limiting instruction on prior convictions.

¶2 Defendant, Suwit Thongjareon, 1 appeals his conviction of aggravated criminal sexual

abuse (720 ILCS 5/11-1.60(c)(1)(i) (West 2018)). He argues that the trial court improperly

1 In the record below, defendant’s name is also spelled Thongjaroen. 2025 IL App (2d) 240344-U

admitted his prior conviction of unlawful restraint as impeachment evidence under People v.

Montgomery, 47 Ill. 2d 510 (1971).

¶3 I. BACKGROUND

¶4 On September 8, 2021, the State charged defendant in case No. 21-CF-1196 with one count

of aggravated criminal sexual abuse. The State alleged that, between May 26, 2020, and April 24,

2021, defendant placed his hand on the vagina of his stepdaughter, J.V., for the purpose of his

sexual arousal.

¶5 On November 29, 2021, the State charged defendant in case No. 21-CF-1694 with unlawful

restraint. The State alleged that, on or about August 10, 2021, defendant “prevented [E.R., his

wife,] from leaving by grabbing, pulling, and/or using his body to keep [E.R.] in place.”

¶6 The cases proceeded in parallel, with the State electing to try defendant first in case No. 21-

CF-1694. After defendant was convicted in case No. 21-CF-1694, the State proceeded to trial in

case No. 21-CF-1196.

¶7 Before trial, on September 27, 2023, the State filed two motions in limine. The first was a

motion under section 115-10 of the Code of Criminal Procedure of 1963 (725 ILCS 5/115-10

(West 2022)) to admit J.V.’s out-of-court statements to her mother, E.R.; her cousin, S.D.; her

aunt, L.D.; and Kasandra Osorio, an investigator with the Kane County Child Advocacy Center

(CAC). The trial court ruled that the statements to family members showed sufficient safeguards

of reliability and were admissible. However, the court ruled that the statements to Osorio were

not sufficiently reliable, because (1) J.V. repeatedly said that defendant touched her

“ ‘inappropriately,’ ” a term not expected of a seven-year-old child, and (2) J.V. did not provide

details about the touching.

-2- 2025 IL App (2d) 240344-U

¶8 The second motion in limine was brought under Montgomery and sought to admit

defendant’s unlawful restraint conviction in case No. 21-CF-1694 to impeach his credibility if he

testified at trial. In particular, the State argued that the conviction met Montgomery’s three-part

test because (1) the offense was punishable by imprisonment in excess of one year; (2) less than

10 years had elapsed since the date of the conviction; and (3) the probative value of admitting the

conviction outweighed the danger of unfair prejudice. See Montgomery, 47 Ill. 2d at 516, 519.

¶9 At the hearing, the State stood on its motion and made no additional argument. Defense

counsel began by noting that, under Montgomery, if “the jury is more likely to decide that the

[prior] offense means that [defendant] is more likely to commit the [charged] offense, then [the

prior conviction] shouldn’t come in.” But “[i]f they’re more likely to believe he’s a liar because

of the nature of the [prior] offense, then it should come in.” Based on these principles, counsel

asked the trial court to exclude the conviction of unlawful restraint. Counsel argued that unlawful

restraint is a “quasi violent offense.” “It’s not aggravated battery but certainly it does not sound

particularly nonviolent to a jury.” According to counsel, “[u]nlike a retail theft, forgery, or some

sort of crime in which the underlying criminal intent is a lie basis [sic] that makes it more likely

[that defendant is] a liar,” a prior unlawful restraint conviction will make it more likely in the jury’s

eyes that defendant committed the charged sex offense. Counsel also noted that the unlawful

restraint conviction was defendant’s only prior conviction and that it was entered less than a year

before the hearing.

¶ 10 The trial court granted the State’s motion to admit the unlawful restraint conviction. The

court explained:

“The Court has had an opportunity to consider the arguments, as well as the case law of

Montgomery and the cases that follow. The unlawful restraint is a Class 4 felony. So

-3- 2025 IL App (2d) 240344-U

[defendant’s] crime [is] punishable in excess of one year. Number two, it’s a 2021 case.

So it’s very recent and within the ten-year period.

So then the [c]ourt must conduct a balance [sic] test and find whether or not the

probative value of admitting the prior conviction outweighs the danger of unfair prejudice.

The unlawful restraint is not a similar type of offense to the aggravated criminal sexual

abuse. The case law does establish that a felony conviction that does not involve dishonesty

still could go towards demonstrating that a person is unwilling—or strike that.

In conducting the balancing test, I find that the probative value of admitting the

prior conviction outweighs the danger of the unfair prejudice. There’s a jury instruction

that instructs the jurors to consider it for credibility purposes. And so if the defendant

testifies, he will be allowed to be impeached with the prior conviction.”

¶ 11 At trial, J.V., age 10, testified first. She testified that defendant had lived with her and E.R.

in an apartment. On one occasion, when she was seven years old, defendant touched her

“inappropriately” under her clothes on her “private area” where she goes “[p]ee.” J.V. stated that

defendant’s hand was “[m]aking movements” as he touched her, and she demonstrated the

movements for the jury. J.V. testified that the touching occurred when she was on the bed in E.R.’s

bedroom. At the time, J.V. was using her tablet for a class, and the camera and microphone were

turned off. J.V. testified that the touching made her uncomfortable and that defendant told her not

to say anything about the touching. J.V. was asked, “After he touched you, can you—do you

remember how it stopped?” J.V. replied no.

¶ 12 On cross-examination, J.V. testified that she told S.D. at a sleepover that defendant “had

tried to touch [her] or look at [her] private part.” Thereafter, J.V. told E.R. that defendant “was

-4- 2025 IL App (2d) 240344-U

trying” to touch her inappropriately. J.V.

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2025 IL App (2d) 240344-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-thongjareon-illappct-2025.