People v. Roberts

Illinois Appellate Court
Criminal Court
Motion to Suppress
Citation
Case Number: 
2020 IL App (1st) 172262
Decision Date: 
Friday, January 22, 2021
District: 
1st Dist.
Division/County: 
Cook Co., 2d Div.
Holding: 
Affirmed.
Justice: 
PUCINSKI

Defendant was convicted, after bench trial, of 3 counts of armed robbery and was sentenced to 3 concurrent terms of 25 years. Counsel's failure to seek suppression of witness's pretrial identification on grounds of police not following procedural requirements in section 107A-2 of Code of Criminal Procedure did not deprive Defendant of his right to effective assistance of trial counsel because Defendant suffered no prejudice. A violation of procedural dictates of the lineup statute does not necessarily have an effect on reliability of a witness's identification. Even if a motion to suppress would have been successful, it would not have altered outcome of trial, as evidence of Defendant's guilt was overwhelming.  (FITZGERALD SMITH and LAVIN, concurring.)