People v. Randolph

Illinois Appellate Court
Criminal Court
Hearsay
Citation
Case Number: 
2014 IL App (1st) 113624
Decision Date: 
Wednesday, March 26, 2014
District: 
1st Dist.
Division/County: 
Cook Co., 3d Div.
Holding: 
Reversed.
Justice: 
MASON
(Court opinion corrected 3/31/14.) Defendant was convicted, after jury trial, of possession of less than 15 grams of cocaine. Court erred in allowing prosecution to elicit testimony from officer as to statements in his report that were consistent with his trial testimony.Questions posed on cross-examination would not permit introduction of prior consistent statements. As State's case hinged entirely on credibility of officers, when officers were impeached with facts omitted from their reports, State should not have been permitted to bolster their credibility with prior consistent statements that did not explain those omissions. (HYMAN and PUCINSKI, concurring.)