People v. Anaya

Illinois Appellate Court
Criminal Court
Evidence
Citation
Case Number: 
2020 IL App (1st) 170839
Decision Date: 
Tuesday, May 26, 2020
District: 
1st Dist.
Division/County: 
Cook Co., 2d Div.
Holding: 
Affirmed.
Justice: 
FITZGERALD SMITH

Defendant was convicted, after bench trial, of 1 count of armed habitual criminal and 1 count of possession of a firearm by a felon. State admitted that it lost the squad car dash camera video exhibit shown at trial and relied upon by both parties in closing argument. Video footage is neither exculpatory nor material to any credibility determination and thus is not indispensable to a sufficiency of evidence challenge; testimony of State's 2 eyewitnesses supplies an adequate substitute.(LAVIN and COGHLAN, concurring.)