People v. Valladeres

Illinois Appellate Court
Criminal Court
Accountability Theory
Citation
Case Number: 
2013 IL App (1st) 112010
Decision Date: 
Wednesday, July 24, 2013
District: 
1st Dist.
Division/County: 
Cook Co., 3d Div.
Holding: 
Affirmed.
Justice: 
HYMAN
Defendant was convicted, under accountability theory, of first degree murder and aggravated battery with a firearm. Defendant maintained that he had no idea that the gun he provided to a fellow gang member would be used to commit a crime. Defense counsel's representation was not ineffective, as decisions to not file motions to suppress statements to police or limit admission of gang evidence were matters of trial strategy. Court properly instructed jury with IPI on accountability, as it informed jury of law. Court's voir dire questions about accountability was legally permissible; even though court did not then mention mens rea, impaneled jury was informed three separate times of requisite intent for accountability conviction. (NEVILLE and MASON, concurring.)