Illinois Supreme Court
Criminal Court
Death Penalty
Evidence
Defendant was convicted, after jury trial, of first-degree murder of his parents, sister, and brother-in-law. Court properly applied forfeiture by wrongdoing doctrine and properly admitted testimony of Defendant's other sister that deceased sister had called her six weeks prior to murders and told sister that he would kill her if she told them that he had obtained credit in their parents' names. Court properly admitted testimony of detective that sister initially gave opinion that Defendant was involved in murders, and properly admitted computer records of airline (on which Defendant flew to California shortly after murders) indicating that Defendant was dangerous. Circuit court properly denied Defendant's burdensome subpoena requests to conduct statewide review of murder cases, both death penalty and non-death penalty. Illinois death penalty statute conforms to Supreme Court's Eighth Amendment analysis and does not run afoul of its Apprendi v. New Jersey decision. (FITZGERALD, FREEMAN, THOMAS, KILBRIDE, KARMEIER, and BURKE, concurring.)