Illinois Appellate Court
Criminal Court
Evidence
Defendant was found guilty of two counts of first-degree murder for the fatal beating of his girlfriend and was sentenced to 55 years in prison. On appeal, defendant argued that the admission of the victim’s hearsay statements to law enforcement officers about prior incidents of domestic violence violated the confrontation clause and that those statements as well as statements that the victim made to acquaintances were inadmissible hearsay. The appellate court affirmed, finding that the trial court properly applied the doctrine of forfeiture by wrongdoing as an exception to both the confrontation clause and the rule against hearsay. (STEIGMANN and VANCIL, concurring)