People v. Williams
| Docket Number | 2-20-0455 |
| Decision Date | 28 December 2022 |
| Citation | 225 N.E.3d 56 |
| Parties | The PEOPLE of the State of Illinois, Plaintiff-Appellee, v. Douglas WILLIAMS, Defendant-Appellant. |
| Court | United States Appellate Court of Illinois |
Appeal from the Circuit Court of Winnebago County. No. 19-CF-1453, Honorable Debra D. Schafer, Judge, Presiding.
James E. Chadd, Douglas R. Hoff, and Abigail Hogan Elmer, of State Appellate Defender’s Office, of Chicago, for appellant.
J. Hanley, State’s Attorney, of Rockford (Patrick Delfino, Edward R. Psenicka, and Miles J. Keleher, of State’s Attorneys Appellate Prosecutor’s Office, of counsel), for the People.
¶ 1 Following, a jury trial in the circuit court of Winnebago County, defendant, Douglas Williams, was convicted of first degree murder (720 ILCS 5/9-1(a)(1), (b)(16) (West 2018)). The trial court sentenced defendant to a term of 70 years’ imprisonment. Defendant appeals, raising the following issues. First, defendant argues that the trial court erred in honoring his personal demand, to proceed to trial over the objection of his own attorney and "in the midst of an unprecedented global pandemic." Second, defendant argues that the trial court erred by refusing to ask potential jurors during voir dire certain questions tendered by defense counsel designed to elicit COVID-19-related concerns and possible biases. Third, defendant argues that other COVID-19-related measures, including mandatory masking of the venire and social-distancing protocols, denied him a fair trial. Fourth, defendant argues that he was denied a fair trial where the State was permitted to introduce a preinterrogation video of him cursing and acting belligerently. Fifth, defendant argues that he was denied a fair trial by the State’s remarks regarding his demeanor made during closing argument. Finally, defendant argues that he was denied a fair trial where the trial court allowed the jury to view "gruesome [and] unfairly prejudicial" crime scene and autopsy photographs of the victim, Samuel Randolph. For the reasons set forth below, we affirm.
¶ 3 Defendant’s conviction stems from events occurring in Rockford in the early morning hours of April 7, 2019, during which Randolph was beaten to death. Defendant was initially charged in a three-count criminal complaint with various offenses related to Randolph’s death. On July 10, 2019, a grand jury returned an indictment against defendant, charging him with seven counts of first degree murder (720 ILCS 5/9-1(a)(1), (2), (b)(16) (West 2018)). Several counts of the indictment alleged that Randolph was a person 60 years of age or older at the time of the offense and that the offense was accompanied by exceptionally brutal or heinous behavior indicative of wanton cruelty.
¶ 5 On June 13, 2019, defendant appeared before the trial court for arraignment on the charges alleged in the criminal complaint. In response to inquiries from the court, defendant stated that he was 56 years of age, that he had finished school, and that he could read, write, speak, and understand English. Defendant also indicated that he viewed a video that explained his rights, that he understood his rights, and that he received a copy of the complaint filed against him. The court then reviewed with defendant each of the three counts of the complaint and the potential sentences. Defendant pleaded not guilty. The parties next appeared before the court on July 12, 2019. At that hearing, the court informed defendant that the grand jury had returned a seven-count indictment against him. Defense counsel waived a formal reading of rights, charges, and possible penalties and entered a plea of not guilty on all counts.
¶ 6 At a status hearing on October 18, 2019, defense counsel asked the court to set the matter for trial in January. The State agreed, and the court set the matter for January 21, 2020. On January 3, 2020, the State asked for a continuance because the case had been reassigned to a different prosecutor. Over defendant’s objection, the court granted the motion to continue trial until February 18, 2020.
¶ 7 On February 13, 2020, the State moved for a continuance, citing (1) outstanding DNA evidence and (2) the reassignment of the case to yet another prosecutor. During the hearing, defendant repeatedly asked about the 120-day speedy-trial term. The State responded that no more than 60 days would be attributable to it as of February 18. Defense counsel indicated that the State’s estimation was correct. Moreover, defense counsel did not object to the continuance, noting, among other things, that the DNA evidence could potentially exclude defendant as the offender. Ultimately, the trial court granted the State’s motion and continued the trial to March 2, 2020. At a -status hearing on February 21, 2020, the court continued the case by agreement of the parties and set trial for April 6, 2020.
¶ 8 On March 20, 2020, defense counsel filed a motion to continue the trial due to the COVID-19 pandemic. At the hearing on the motion, defense counsel expressed concerns about defendant’s ability to receive a fair jury trial during the pandemic. Defense counsel requested that the matter be continued to May or June. Defendant voiced his opposition to the motion. The State did not object to the motion. The trial court did not rule on the motion on that date. At a hearing on March 24, 2020, the court told defendant that "the [Illinois] Supreme Court has indicated basically all speedy trial demands are on hold" due to COVID-19. Defendant responded, "Well, I still want mine, and I ain’t changing my mind." The trial court then set the case for a jury trial on June 1, 2020, over defendant’s personal objection.
¶ 9 On May 15, 2020, defense counsel filed a motion to continue trial. A hearing on the motion was held on May 21, 2020. At that hearing, defense counsel argued that, due to COVID-19, a jury would not be able to focus on evidence or deliberate fully, and, therefore, there was no way to have a fair trial under the circumstances. Defendant told the trial court that he wanted to proceed with the trial, stating:
The court told defendant that it wanted to explain how a trial would be conducted during the pandemic. Defendant responded, The court then informed defendant that a trial conducted during a pandemic would be different. The court stated that defendant’s case would act as a "guinea pig," since it would be one of the first trials held during the pandemic. The court noted that, due to issues of social distancing, trials would be conducted in only the two largest courtrooms. The court further noted that the jurors would be spread out throughout the courtroom, perhaps seated in a way that they could hear defendant’s conversations with defense counsel or see defense counsel’s computer screen. The court also indicated that the jury-selection process would take longer because of limits on the number of potential jurors they could voir dire at one time and that the jury deliberation room would be rearranged to promote social distancing. The court asked defendant if he had any questions about the procedure for the trial. Defendant responded, The State indicated that it had no objection to a continuance. In response to an inquiry from the court, both sides indicated that, other than the COVID-19 issues, they were ready to proceed to trial. The court then took a recess to consider its ruling.
¶ 10 Following the recess, defense counsel argued that it was the attorney’s decision, not defendant’s, to continue trial. The trial court then explained additional procedures that would be implemented because of the pandemic. The court stated:
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