Defendant was convicted, after jury trial, of murder and armed robbery. FBI agent was qualified to testify as expert under Illinois Rule of Evidence Rule 705 in field of historical cell site analysis, and he thoroughly explained basis for his testimony establishing sufficient foundation for his findings. Court properly admitted Agent's testimony as to time and location of cell towers used by Defendant's phone.Court promptly struck detective's comment as to his search for "criminal history", and no direct evidence presented at trial that Defendant had engaged in criminal conduct prior to offense for which he was charged. State's remarks in rebuttal as to a grand conspiracy theory were invited by Defendant's remarks in closing argument.(PIERCE, concurring; HYMAN, dissenting.)
Illinois Appellate Court
Criminal Court
Expert Witnesses