People v. Chatman

This case presents question in instant felony murder trial as to whether trial court properly granted State’s motion in limine to admit recorded statements of witness under Rule 804(b)(5), which allows introduction of such recording under doctrine of forfeiture by defendant’s wrongdoing, where said witness was unavailable for trial. While defendant argued that State failed to make required showing that said witness was “unavailable” for trial, Appellate Court found that State adequately established witness’s unavailability, where police officials placed notice on local I-Board system, attempted to contact witness on his phone, attempted to locate witness at several addresses in Illinois and Iowa, and attempted to locate witness through defendant’s mother and witness’s brother. Appellate Court further noted that there was no evidence of any leads that police had failed to follow up on.