People v. Harris

Defendant, who was 15 years old at the time of the offense, was convicted of first-degree murder and attempted murder and was sentenced to a total of 35 years. Defendant appealed claiming that the juvenile court erred in transferring the case to adult criminal court, the trial court failed to comply with Supreme Court Rule 431(b), and the trial court erred in admitting hearsay statements under the course-of-investigation exception to the hearsay rule. The State conceded that the trial court failed to comply with Rule 421(b), but argued that the evidence was not closely balanced and that the error was forfeited. The appellate court affirmed, finding the trial court did not abuse its discretion when it balanced the statutory factors to be considered to transfer the case to adult court. The appellate court further found that while the trial court failed to comply with Rule 431(b), the defendant did not meet his burden of showing that the evidence was closely balanced. The court also found that the hearsay statements that were admitted went beyond what was required to explain the officer’s course of investigation, but that there was no reasonable possibility that the verdict would have been different if the hearsay had been excluded. (McBRIDE and ELLIS, concurring)