People v. Wilson

2022 IL App (3d) 190172-U
CourtAppellate Court of Illinois
DecidedJanuary 11, 2022
Docket3-19-0172
StatusUnpublished

This text of 2022 IL App (3d) 190172-U (People v. Wilson) 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. Wilson, 2022 IL App (3d) 190172-U (Ill. Ct. App. 2022).

Opinion

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

2022 IL App (3d) 190172-U

Order filed January 11, 2022 ____________________________________________________________________________

IN THE

APPELLATE COURT OF ILLINOIS

THIRD DISTRICT

THE PEOPLE OF THE STATE OF ) Appeal from the Circuit Court ILLINOIS, ) of the 10th Judicial Circuit, ) Peoria County, Illinois, Plaintiff-Appellee, ) ) Appeal No. 3-19-0172 v. ) Circuit No. 17-CF-575 ) WADE W. WILSON, ) Honorable ) Paul P. Gilfillan, Defendant-Appellant. ) Judge, Presiding. ____________________________________________________________________________

JUSTICE DAUGHERITY delivered the judgment of the court. Presiding Justice O’Brien and Justice Lytton concurred in the judgment. ____________________________________________________________________________

ORDER

¶1 Held: The circuit court did not abuse its discretion (1) by admitting other-crimes evidence, and (2) in refusing a lesser-included offense instruction.

¶2 Defendant, Wade W. Wilson, appeals his conviction for armed robbery. Defendant

argues that the Peoria County Circuit court erred in allowing evidence of other crimes and

refusing an instruction on attempted armed robbery. We affirm.

¶3 I. BACKGROUND ¶4 The State charged defendant with armed robbery (720 ILCS 5/18-2(a)(2) (West 2016)).

The matter proceeded to a jury trial where the State pursued a conviction on an accountability

theory.

¶5 Drake Davis testified that defendant contacted him through Facebook messenger and

arranged to meet him at a gas station in order to purchase marijuana from Davis. When

defendant arrived at the gas station, Davis approached his vehicle and defendant asked him to sit

in the back seat of the vehicle. There was an individual in the front passenger seat, later

identified as Kareem Dixon. They drove to another location. Defendant “said he was sorry he

had to do this.” Dixon pointed a handgun at Davis’s face and demanded that Davis “empty out

[his] pockets, take off [his] shoes, even [his] phone, [his] wallet.” When asked what was actually

taken from him, Davis replied “[a] half ounce of marijuana. My wallet. My bank card. My Social

Security card. Wallet. And my phone.” The State admitted into evidence, and Davis identified, a

Facebook message he received from defendant after the robbery which stated “I’m glad that shits

over bro I just was forced to poke like five people because of that shit!! PS I save ur wallet and

phone so if u can read this.”

¶6 Detective Lee Hoffman testified that defendant described the weapon and showed him a

photograph of the gun on his phone. The State admitted into evidence photographs obtained from

defendant’s phone showing defendant with the gun utilized in the robbery. Defendant also told

Hoffman where he would be able to find the gun.

¶7 Outside the presence of the jury, defendant objected to the introduction of portions of his

recorded interview with the police wherein he discussed other crimes. The State argued initially

that it was admissible to prove defendant’s knowledge and intent to rob Davis and later that it

also showed a common plan or scheme between defendant and Dixon to rob people. The court

2 noted that the discussion of other crimes was “pretty inflammatory stuff,” but also noted that

“[e]verything is prejudicial when it comes in against the defendant.” The court found most of the

other-crimes evidence to be too prejudicial and excluded it, but the court determined the State

could admit a portion wherein defendant discussed a prior robbery with Dixon.

¶8 Lieutenant Chris Watkins testified that he interviewed defendant and defendant explained

that he had been involved in a prior, separate robbery with Dixon. The State introduced the

recording of the portion of Watkins’s interview with defendant wherein he discussed the other

robbery. Subsequently, the court instructed the jury that “Evidence has been received that the

defendant has been involved in conduct other than that charged in the indictment. This evidence

has been received on the issue of the defendant’s intent and knowledge and may be considered

by you only for that limited purpose.”

¶9 Defense counsel proposed a jury instruction on attempted armed robbery. The State

argued that defendant was not entitled to that instruction because there was no evidence to

contradict the fact that the robbery was completed. The court refused the instruction.

¶ 10 The jury found defendant guilty. Defendant moved for a new trial, arguing, in part, that

the court erred in allowing other-crimes evidence and refusing his proposed jury instruction. The

court denied the motion. The court sentenced defendant to a term of 21 years and 6 months’

imprisonment. Defendant appeals.

¶ 11 II. ANALYSIS

¶ 12 A. Other-Crimes Evidence

¶ 13 Defendant argues that the circuit court abused its discretion in admitting the portion of

defendant’s recorded interview wherein he discussed a prior, separate robbery. Defendant asserts

3 that the weakness of the State’s case exacerbated the prejudice of admitting the evidence and that

the purported bases for admitting the evidence, intent and modus operandi, were not at issue.

¶ 14 The decision to admit other-crimes evidence is reviewed for an abuse of discretion.

People v. Donoho, 204 Ill. 2d 159, 182 (2003). An abuse of discretion exists when the court’s

decision is arbitrary, fanciful or unreasonable or when no reasonable person would take the

position of the circuit court. Id. Generally, evidence of a defendant’s prior crimes is inadmissible

because it is so persuasive of defendant’s propensity to commit crimes that it becomes unfairly

prejudicial. Id. at 170. Illinois Rule of Evidence 404(b) (eff. Jan. 1, 2011) permits character

evidence for “purposes, such as proof of motive, opportunity, intent, preparation, plan,

knowledge, identity, or absence of mistake or accident.” But, other-crimes evidence “may still be

excluded from evidence if its prejudicial effect substantially outweighs its probative value.”

People v. Petrakis, 2019 IL App (3d) 160399, ¶ 22; see also Ill. R. Evid. 403 (eff. Jan. 1, 2011).

¶ 15 Here, the State pursued the armed robbery charge on an accountability theory. To hold

defendant accountable for Dixon’s conduct, the State needed to prove that defendant “with the

intent to promote or facilitate” the armed robbery, solicited, aided, abetted, agreed, or attempted

to aid Dixon in the planning or commission of the armed robbery. See 720 ILCS 5/5-2(c) (West

2016). Thus, defendant’s intent was an element the State needed to prove. Even if we accept

defendant’s contention that he did not put his intent at issue, “the State can introduce otherwise

admissible other-crimes evidence to prove intent even where the defendant does not put intent

directly in issue.” People v. Davis, 2019 IL App (1st) 160408, ¶ 63. The prior robbery defendant

committed with Dixon is highly probative of defendant’s intent in this matter to promote or

facilitate the armed robbery of Davis. Further, the court gave a limiting instruction regarding this

evidence, which limited any potential prejudice and defendant makes no argument that the jury

4 failed to follow the instruction.

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Related

People v. Reynolds
504 N.E.2d 163 (Appellate Court of Illinois, 1987)
People v. Donoho
788 N.E.2d 707 (Illinois Supreme Court, 2003)
People v. Petrakis
2019 IL App (3d) 160399 (Appellate Court of Illinois, 2019)
People v. Eubanks
2019 IL 123525 (Illinois Supreme Court, 2019)
People v. Davis
2019 IL App (1st) 160408 (Appellate Court of Illinois, 2020)

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2022 IL App (3d) 190172-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-wilson-illappct-2022.