People v. Johnson

The Illinois Supreme Court considered the question of whether a trial court must decide a defendant’s mid-trial motion for a directed verdict before proceeding to the defense’s evidence. The appellate court held that the defendant forfeited the issue on appeal and affirmed the defendant’s conviction and sentence. The Supreme Court held that a trial court must decide the motion before advancing to the defense’s evidence; however, it nevertheless affirmed under a plain error review by finding the error to be harmless. (NEVILLE, OVERSTREET, HOLDER WHITE, concurring and CUNNINGHAM, THEIS, and ROCHFORD, specially concurring)