Illinois Supreme Court
Criminal Court
Jury Instructions; Harmless Error
Defendant was convicted of four counts of aggravated battery of a child and defendant appealed, arguing that the jury instructions on accountability and parental accountability were directly conflicting instructions. The appellate court affirmed and the Supreme Court granted defendant’s petition for leave to appeal. The Supreme Court affirmed defendant’s convictions, finding that any conflict in the required knowledge element in the accountability instruction was harmless error because defendant’s knowledge was not an essential element when defendant was proven guilty of aggravated battery of a child beyond a reasonable doubt. (THEIS, NEVILLE, OVERSTREET, HOLDER WHITE, and CUNNINGHAM, concurring. ROCHFORD took no part in the decision