People v. Fulmer

Illinois Appellate Court
Criminal Court
Citation
Case Number: 
2013 IL App (4th) 120747
Decision Date: 
February 25, 2013
District: 
4th Dist
Division/County: 
Pike Co.
Justice: 
STEIGMANN
Holding: 
Affirmed.
Defense counsel posted on YouTube and his Facebook page a video he received from State's Attorney prior to preliminary hearing depicting Defendant interacting with undercover police at time of alleged offense of unlawful delivery of a controlled substance. Court properly found that defense counsel had violated Supreme Court Rule 415(c) and as a sanction ordered him to remove video from websites. Defense counsel's use of video was improper use of State's early delivery of discovery materials. Whether video was tendered prior to or after preliminary hearing did not affect applicability of Rule 415(c). (APPLETON and TURNER, concurring.)