People v. Crow III 

Defendant was convicted of domestic battery after jury trial, during which he did not testify. Court erred in not instructing jury as to fourth Zehr principle, that a Defendant's failure to testify should not be considered. However, error did not prejudice Defendant, as the evidence was overwhelming against him. Defendant's wife and 14-year-old daughter both had given prior statements to police confirming that Defendant had grabbed his wife's face and scratched it, and struck her head against the front door; their testimony recanting the statements was not credible. Defendant rejected court's offer to give jury instruction as to the subject matter of the fourth Zehr principle, and no evidence was presented that showed jury was biased. (KNECHT and TURNER, concurring.)