People v. Wilmer

2026 IL App (3d) 240669-U
CourtAppellate Court of Illinois
DecidedFebruary 9, 2026
Docket3-24-0669
StatusUnpublished

This text of 2026 IL App (3d) 240669-U (People v. Wilmer) 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. Wilmer, 2026 IL App (3d) 240669-U (Ill. Ct. App. 2026).

Opinion

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

2026 IL App (3d) 240669-U

Order filed February 9, 2026 ____________________________________________________________________________

IN THE

APPELLATE COURT OF ILLINOIS

THIRD DISTRICT

THE PEOPLE OF THE STATE OF ) Appeal from the Circuit Court ILLINOIS, ) of the 18th Judicial Circuit, ) Du Page County, Illinois, Plaintiff-Appellee, ) ) Appeal No. 3-24-0669 v. ) Circuit No. 22-CM-1638 ) ANGEL J. WILMER, ) Honorable ) Jill Otte, Defendant-Appellant. ) Judge, Presiding. ____________________________________________________________________________

JUSTICE HOLDRIDGE delivered the judgment of the court. Justices Brennan and Bertani concurred in the judgment. ____________________________________________________________________________

ORDER

¶1 Held: (1) The circuit court’s exclusion of improper state-of-mind testimony was not an abuse of discretion. (2) The defendant’s convictions for battery violated the one- act, one-crime rule.

¶2 The defendant, Angel J. Wilmer, appeals her battery convictions, arguing that (1) the

Du Page County circuit court denied her a meaningful opportunity to present a complete defense

by excluding relevant evidence concerning her state of mind and (2) her convictions violate the

one-act, one-crime rule. ¶3 I. BACKGROUND

¶4 Following a jury trial, 1 the defendant was convicted of two counts of battery (720 ILCS

5/12-3(a)(1), (2) (West 2022)). Count I alleged that the defendant knowingly and without legal

justification, caused bodily harm to Cheryl Barriga by scratching Barriga about the face. Count II

similarly alleged that the defendant made physical contact of an insulting or provoking nature

when she scratched Barriga about the face.

¶5 Relevant to this appeal, the evidence presented at trial established that on September 27,

2022, the defendant was employed as a rideshare driver and had transported a patient to a dialysis

clinic where Barriga was employed as a nurse. Upon arrival, the defendant walked through the

vestibule at the front entrance and entered the lobby, where she informed Barriga that the patient

needed assistance getting out of the defendant’s vehicle and into the clinic. Barriga explained that

it was against clinic policy for staff to exit the building and that she would need to contact the

patient’s nursing home to verify that the patient had tested negative for COVID-19. The defendant

waited in the lobby while Barriga called the nursing home.

¶6 Barriga testified that after calling the nursing home, she was instructed by the clinic’s

administrator to assist the patient in exiting the defendant’s vehicle. Barriga then returned to the

lobby accompanied by Robin Varughese, a clinic technician. The defendant was upset and raised

her voice as she told Barriga that she was late for work and might lose her other job because

Barriga had refused to take the patient immediately upon arrival. The defendant stated that she was

going to call the police and pointed her finger near Barriga’s face. Barriga raised her hand to protect

herself and told the defendant to stop pointing. After advising the defendant that they would assist

1 A six-person jury was impaneled at the defendant’s request.

2 the patient out of her vehicle, Barriga and Varughese followed the defendant out of the lobby and

into the front entrance vestibule. While inside the vestibule, the defendant hit Barriga in the face.

Barriga’s glasses fell off when the defendant hit her and she sustained a scratch below her right

eye.

¶7 Surveillance video from the clinic showed that as the defendant approached the front door

to exit the building, she turned and struck Barriga in the face. The defendant then lunged forward

at Barriga and continued trying to hit her as Barriga backed away. Varughese moved in front of

Barriga to block the defendant and Barriga exited the vestibule back into the lobby. Barriga briefly

reentered the vestibule and grabbed her glasses as Varughese continued to stand in between her

and the defendant.

¶8 The defendant testified that while she waited in the lobby for Barriga to contact the nursing

home, another clinic employee assisted the patient in exiting her vehicle. When Barriga and

Varughese returned to the lobby, they reiterated to her that they could not assist with helping the

patient exit her vehicle because it was against clinic policy. The defendant indicated she was

annoyed because the patient was already out of her vehicle and she was late for work. As she

turned to leave, Barriga and Varughese followed her into the vestibule. Barriga raised her hand

and pointed her finger at the defendant. The defendant testified that she felt threatened and

potentially in danger. Barriga’s outstretched finger struck the rim of the defendant’s glasses, and

she reacted by hitting Barriga in self-defense. Once the altercation ended, the defendant returned

to her vehicle and called the police. In police body camera footage, the defendant indicated she

wanted to press charges against Barriga and stated that she had injured Barriga while acting in

self-defense.

3 ¶9 During the defendant’s direct testimony, she was asked if she had been involved in any

prior “domestic incident[s]” earlier that year. The defendant answered affirmatively and said that

she was a former victim of domestic violence. The State objected based on relevance. Defense

counsel argued the testimony was relevant, as it related to the defendant’s state of mind at the time

of the charged offenses. The court sustained the objection.

¶ 10 The jury subsequently found the defendant guilty of two counts of battery and the court

imposed concurrent one-year terms of court supervision for each conviction. The defendant filed

a motion for a new trial, arguing, inter alia, that the court erred in sustaining the State’s objection

to her testimony regarding her history as a domestic violence survivor. The court denied the

motion.

¶ 11 II. ANALYSIS

¶ 12 A. State-of-Mind Testimony

¶ 13 On appeal, the defendant first contends that the circuit court erred when it sustained the

State’s objection to her testimony about her involvement with any prior domestic violence

incidents. The defendant argues her purported history as a domestic violence survivor was relevant

to her claim of self-defense because it demonstrated her state of mind at the time of the occurrence

and that barring this evidence deprived her of her constitutional right to have a meaningful

opportunity to present a complete defense.

¶ 14 When a defendant alleges that she acted in self-defense, she is entitled to present evidence

concerning her state of mind to demonstrate that she reasonably believed that the force she used

was necessary to protect herself. See People v. Damnitz, 269 Ill. App. 3d 51, 59 (1994). Although

prior encounters with the victim may be relevant to show a defendant’s state of mind when

asserting self-defense, testimony of unrelated encounters with individuals that are not involved

4 with the occurrence at issue, “would open the door to irrelevant, collateral and unconnected

matters.” People v. Ruel, 120 Ill. App. 2d 374, 379 (1970). Proffered evidence may be rejected as

irrelevant when it provides little probative value due to remoteness, uncertainty, or potential

prejudice. People v.

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2026 IL App (3d) 240669-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-wilmer-illappct-2026.