Supreme Court Summaries
Opinions filed March 22, 2012
People v. Chapman, 2012 IL 111896
Appellate citation: No. 3-07-0799 (unpublished order under Supreme Court Rule 23).
JUSTICE THOMAS delivered the judgment of the court, with opinion.
Chief Justice Kilbride and Justices Freeman, Garman, Karmeier, Burke, and Theis concurred in the judgment and opinion.
In February of 2005, a woman was stabbed to death in the Joliet apartment she shared with this defendant, and he was subsequently convicted of her first degree murder. At Chapman’s Will County trial, he did not testify, but the jury heard the testimony of a police detective to whom he had initially made statements, and it also heard audio tapes of those interviews. According to this version of events given by the defendant, when he arrived from work at 9:45 in the evening, the victim began yelling at him, and when they got into bed, she yelled at him again, and then stabbed him. He claimed he grabbed the knife and stabbed her multiple times before leaving the premises. A driver passing by saw him bleeding in the street and dialed 911. It was later determined that the knife wounds sustained by the victim had struck her carotid artery and jugular vein. A 60-year term was imposed.
The defendant had previously been convicted of a domestic battery of the same victim which had occurred in October of 2003. The State asked for, and received, permission to introduce that earlier conviction into evidence pursuant to a statutory exception, and the defendant claimed on appeal that this was error. The appellate court did not agree and affirmed the conviction, and Chapman appealed.
At common law, evidence of other crimes was inadmissible to show propensity to commit crime, but was admissible for other specified purposes if its probative value substantially outweighed its prejudicial effect. Illinois has partially abrogated this rule by section 115-20 of the Code of Criminal Procedure of 1963, which provides that evidence of a prior conviction of a defendant for “domestic battery [or] aggravated battery committed against a family or household member *** is admissible in a later criminal prosecution for any of these types of offenses when the victim is the same person *** and may be considered for its bearing on any matter to which it is relevant.” There was no dispute that this victim was a household member. Chapman argued that a murder trial was not specified as one of the circumstances in which one of those earlier convictions could be admitted, while the prosecution argued that a subsequent murder trial is included by the language “any of these types of offenses.” In this decision, the supreme court agreed with the State, as the appellate court had done, holding that the murder of a family or household member involving an incident of domestic violence is the functional equivalent of the domestic battery or aggravated battery referred to in the statute.
The results below were affirmed.