People v. Crawford

Illinois Appellate Court
Criminal Court
Battery
Citation
Case Number: 
2021 IL App (5th) 170496
Decision Date: 
Friday, June 11, 2021
District: 
5th Dist.
Division/County: 
Saline Co.
Holding: 
Reversed and remanded.
Justice: 
VAUGHAN

Defendant was convicted, after jury trial, of aggravated battery for causing bodily harm to another in a public place of accommodation or amusement, allegedly by striking a man in the back of the head with a beer bottle at a bar. Five days before trial, State filed additional charges on Defendant, stemming from incident involving a shooting in parking lot of that same bar, on the same date, which occurred after man was hit with a beer bottle. Neither the physical evidence nor surveillance video indicated that Defendant hit the man. The case depended on witness testimony, and evidence was closely balanced. Court erred in allowing State to improperly elicit testimony regarding Defendant's prior bad acts and other crimes to bolster its witness's credibility. Court erred in allowing State to improperly elicit details about the shooting, including threats made by Defendant, and its use of the shooting as substantive evidence of Defendant's guilt threatened to tip the scales of justice against Defendant. (CATES and WHARTON, concurring.)