People v. Maggio

Illinois Appellate Court
Criminal Court
Jury Deliberations
Citation
Case Number: 
2026 IL App (3d) 250013
Decision Date: 
Thursday, January 15, 2026
District: 
3d Dist.
Division/County: 
Will Co.
Holding: 
Affirmed.
Justice: 
PETERSON

Defendant appealed from his convictions for two counts of first-degree murder, arguing that the circuit court abused its discretion by denying his motion in limine to admit evidence of an alternative suspect on the basis that the evidence was remote and speculative. Defendant also argued that the State failed to prove him guilty beyond a reasonable doubt and that the trial court abused its discretion when it denying his motion for mistrial after the jury deliberated for more than 10 hours and instructed the jury to continue deliberating despite being informed that the deliberations had become “heated.” The appellate court affirmed, finding that the trial court did not err in the admission of evidence, that there was sufficient evidence from which a jury could conclude that defendant was guilty beyond a reasonable doubt, and that the trial court did not abuse its discretion when it instructed the jury to continue to deliberate after allowing for a requested break in deliberations. (BRENNAN and ANDERSON, concurring)