People v. Amigon

Defendant, age 18 at time of incident, was convicted of murder and aggravated battery with a firearm, from a gang-related shooting which resulted in one death and one wounding which rendered a victim a quadriplegic from spinal cord damage; that victim died of pneumonia five years later at age 22. After this death, jury convicted Defendant of first-degree murder for this victim's death. State presented sufficient causation evidence, as physician who performed autopsy concluded that victim, who never fully recovered from shooting, died as a result of quadriplegia, given his significant medical wasting, as a result of gunshot wound to the neck. Electronic recording requirement for custodial statements does not apply retroactively to bar the admission of Defendant's custodial statement made nearly 10 years prior to effective date of requirement. (FREEMAN, THOMAS, GARMAN , KARMEIER, BURKE, and THEIS, concurring.)