People v. Walker

Illinois Appellate Court
Criminal Court
Citation
Case Number: 
2012 IL App (2d) 110288
Decision Date: 
December 31, 2012
District: 
2d Dist.
Division/County: 
Du Page Co.
Justice: 
HUTCHINSON
Holding: 
Affirmed.
(Court opinion corrected 1/23/13.) Defendant was convicted of first-degree murder under felony-murder theory for beating. Victim's wife refused to consent to blood transfusion for victim based on religious reasons. Court properly refused to give jury instruction on causation that may apply in felony-murder cases, as Defendant's theory at trial was not that victim died from unforeseeable circumstance, but that evidence did not show that he was perpetrator. Refusal of transfusion was not intervening cause sufficient to render Defendant not liable for victim's death. (McLAREN and BURKE, concurring.)