People v. Howe

Illinois Appellate Court
Criminal Court
Sexually Dangerous Persons
Citation
Case Number: 
2014 IL App (4th) 140054
Decision Date: 
Monday, November 24, 2014
District: 
4th Dist.
Division/County: 
Scott Co.
Holding: 
Affirmed.
Justice: 
TURNER
State filed petition to have Defendant declared a sexually dangerous person, which court granted. State did not violate Defendant's due process rights, per Brady v. Maryland, in failing to disclose victim's statement until third day of trial. Statement did not prejudice Defendant, and statement did not put whole case in such a different light as to undermine confidence in outcome. Principles of Brady v. Maryland apply in proceedings where Defendant is sought to be declared a sexually dangerous person. (APPLETON and KNECHT, concurring.)