People v. Pelo

Bloomington police sergeant was convicted, after jury trial, of 37 counts of criminal conduct involving stalking, intimidation, home invasion, residential burglary, unlawful restraint, and aggravated criminal sexual assault of five women from the Bloomington-Normal area. Because Defendant failed to make an adequate formal offer of proof as to expert testimony, reviewing court cannot know whether the excluded testimony would have been admissible and would have aided the jury. Trial court recited Zehr principles to jurors at start of voir dire and also questioned the jurors as to their understanding and acceptance after dividing jurors into smaller panels where they collectively acknowledged their understanding and acceptance of principles, including that the Defendant was presumed innocent. Thus, court complied with Rule 431(b) in voir dire. Evidence was sufficient to show that the same perpetrator committed all the crimes in the case, and they were "signature crimes" of the same assailant. Statutory offense of aggravated criminal sexual assault predicated upon accused having been armed with a firearm violates the proportionate-penalties clause. (TURNER and APPLETON, concurring.)