People v. Jefferson

This case presents question as to whether trial court properly granted defendant’s motion to preclude State in retrial on murder charge from presenting evidence alleging that defendant fired gun that caused victim’s death, where jury in first trial found in special interrogatory that State had failed to present sufficient evidence to establish that defendant had fired gun that caused victim’s death. Appellate Court, in considering State’s appeal of trial court’s order pursuant to Rule 604(a)(1), reversed trial court and held that doctrine of direct estoppel did not apply, where jury’s response to special interrogatory applied only to sentence enhancement issue and not general verdict of defendant’s guilt. In his petition for leave to appeal, defendant argued that state could not appeal trial court’s order under Rule 604(a)(1), and that estoppel applied to jury’s response to special interrogatory.