People v. Whetstone

2020 IL App (2d) 170919-U
CourtAppellate Court of Illinois
DecidedAugust 17, 2020
Docket2-17-0919
StatusUnpublished
Cited by1 cases

This text of 2020 IL App (2d) 170919-U (People v. Whetstone) 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. Whetstone, 2020 IL App (2d) 170919-U (Ill. Ct. App. 2020).

Opinion

2020 IL App (2d) 170919-U No. 2-17-0919 Order filed August 17, 2020

NOTICE: This order was filed under Supreme Court Rule 23 and may not be cited as precedent by any party except in the limited circumstances allowed under Rule 23(e)(1). ______________________________________________________________________________

IN THE

APPELLATE COURT OF ILLINOIS

SECOND DISTRICT ______________________________________________________________________________

THE PEOPLE OF THE STATE OF ) Appeal from the Circuit Court ILLINOIS, ) of Kane County. ) Plaintiff-Appellee, ) ) v. ) No. 14-CF-74 ) CHRISTOPHER WHETSTONE, ) Honorable ) John A. Barsanti, Defendant-Appellant. ) Judge, Presiding. ______________________________________________________________________________

JUSTICE JORGENSEN delivered the judgment of the court. Justices McLaren and Bridges concurred in the judgment.

ORDER

¶1 Held: Defendant was not denied a fair trial through jury bias, other-crimes evidence, ineffective representation, or prosecutorial misconduct. Affirmed.

¶2 On January 13, 2014, Rachel Taylor died after being shot on a driveway near defendant’s,

Christopher Whetstone’s, home in Aurora. After a jury trial, defendant was convicted of first-

degree murder (720 ILCS 5/9-1(a)(1) (West 2016)) and sentenced to 60 years’ imprisonment.

¶3 On appeal, defendant argues that he was deprived of his right to a fair and impartial trial

for four overarching reasons: (1) jury irregularities and bias; (2) improper injection of other-crimes

evidence; (3) ineffective assistance where his counsel failed to object to the introduction of dog- 2020 IL App (2d) 170919-U

tracking evidence; and (4) one of the prosecutors engaged in unprofessional conduct during closing

arguments. For the following reasons, we affirm.

¶4 I. BACKGROUND

¶5 Defendant was charged with two counts of first-degree murder in connection with Taylor’s

death. Taylor was defendant’s ex-girlfriend and the mother of his two children, who were in a

vehicle in the driveway when their mother was killed.

¶6 Prior to trial, the court denied defendant’s motion to transfer venue due to local publicity,

subject to renewal after jury selection. The court also denied defendant’s motion to suppress

certain statements that he made upon arrest and while pending transport to the police station.

Defendant’s motion in limine to admit evidence of his theory of the case, namely, that Taylor was

killed in a gang-related, drive-by shooting, was denied. However, the court granted defendant’s

motion in limine to bar reference to defendant’s prior bad acts or convictions.

¶7 A. Jury Selection and Notes

¶8 i. Questioning Regarding Racial Bias

¶9 During jury selection, one of defendant’s attorneys asked a prospective juror about the

diversity of the community in which that juror lived. After objection, counsel explained that the

questions were intended to explore implicit racial bias. The court sustained the State’s objection

on the basis that race was not an issue in the case, given that defendant was African-American,

and Taylor was white and African-American. Defense counsel noted that defendant was the only

African-American person in the courtroom and further argued that studies show that implicit racial

biases may impact how jurors hear evidence and consider guilt. The court stated that it would

permit counsel to ask jurors if they would be biased against defendant because of his race, but that

questions concerning diversity or where they grew up were “too far afield.” Defense counsel asked

-2- 2020 IL App (2d) 170919-U

jurors if defendant’s race would affect their deliberations, and they each responded in the negative.

Similarly, counsel asked jurors if they thought that defendant was more likely to be guilty because

he was African-American, and they all answered, “no.”

¶ 10 During a break, defense counsel made a record of defendant’s position concerning

questioning jurors about potential racial bias. Counsel explained that, according to research,

everyone has implicit biases and that it was important to question more deeply whether the jurors

would acknowledge those implicit biases and whether those biases would affect their deliberations.

Counsel again noted that defendant was the only African-American in the courtroom at that point, 1

and that research showed that such biases could alter how a juror both heard evidence and

considered guilt and innocence. Counsel provided the court with an instruction that is purportedly

used in California that defendant suggested should be read to the jury prior to hearing any evidence:

“Each one of us has biases about or certain perceptions or stereotypes of other

people. We may be aware of some of our biases, though we may not share them with

others. We may not be fully aware of some of our other biases.

Our biases often affect how we act, favorably or unfavorably, toward someone.

Bias can affect our thoughts, how we remember, what we see and hear, whom we believe

or disbelieve, and how we make important decisions.

As jurors you are being asked to make very important decisions in this case. You

must not let bias, prejudice, or public opinion influence your decision. You must not be

1 According to the State’s argument on defendant’s motion for a new trial, on the second

day of jury selection, an African-American juror was selected to sit on the jury.

-3- 2020 IL App (2d) 170919-U

biased in favor of or against any party or witness because of his or her disability, gender,

race, religion, ethnicity, sexual orientation, age, national origin, or socioeconomic status.

Your verdict must be based solely on the evidence presented. You must carefully

evaluate the evidence and resist any urge to reach a verdict that is influenced by bias for or

against any party or witness.” 2

¶ 11 The court rejected counsel’s proposed instruction, noting that an African-American

defendant is not constitutionally entitled to question prospective jurors about race. The court

further noted, however, that it would permit some inquiry into whether a juror might be biased

against defendant due to his race. Nevertheless, it would not allow voir dire to morph into

indoctrination and extensive education on the topic. It further noted that it had not received any

proposed questions that counsel would ask the venire, nor would it, at that point, allow any to be

presented.

¶ 12 After jury selection, defense counsel again presented the court with the California

instruction on implicit bias, requesting that it be read to the jury prior to hearing any evidence, as

well as the supporting California canons of judicial ethics, which concerned a trial judge’s

obligation to conduct proceedings free from bias and prejudice (counsel noted that the Illinois

Canons of Judicial Ethics had corollaries), and a 2016 resolution and report from the American

Bar Association, advising that trial courts should advise juries about implicit bias and how it may

2 Although the proposed instruction from California and other similar documents appear in

the record, there are no official citations displayed on those documents, nor does defendant provide

any in his briefs.

-4- 2020 IL App (2d) 170919-U

affect decisionmaking. 3 The court again rejected the request, but read instead to the jury Illinois

Pattern Instruction, Criminal, No. 1.01 (4th ed.

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Bluebook (online)
2020 IL App (2d) 170919-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-whetstone-illappct-2020.