People v. Kendrick

Illinois Appellate Court
Criminal Court
Confrontation
Citation
Case Number: 
2013 IL App (1st) 090120-B
Decision Date: 
Tuesday, May 7, 2013
District: 
1st Dist.
Division/County: 
Cook Co., 2d Div.
Holding: 
Affirmed.
Justice: 
QUINN
Defendant was convicted, after jury trial, of aggravated criminal sexual assault of 16-year-old girl. Trial judge violated Supreme Court Rule 431(b) in not inquiring into prospective jurors' acceptance of two of the three Zehr principles. However, Defendant did not argue on appeal that evidence exists that he was tried before a biased jury; and there is no bright-line rule of reversal for violations of Rule 431(b). Thus, no reversible error. Expert's testimony as to DNA analysis report prepared by another analyst does not violate Defendant's sixth amendment confrontation clause rights. (CONNORS and SIMON, concurring.)