Investigators discovered Defendant was in possession of multiple open Illinois vehicle titles pertaining to various stolen vehicles. Court erred in allowing State to present 11 federal convictions to jury to impeach Defendant's credibility, as they were beyond the strict 10-year requirement of Rule 609(b) of Illinois Rules of Evidence. Court erred in allowing State to impeach Defendant's credibility with proof of guilty for 2010 Cook County charge, because plea had not resulted in sentence and final judgment of conviction. Without convictions and guilty plea, State could not properly urge jury that Defendant's credibility was weakened by his prior convictions. Thus, admission of improper evidence was so egregious that it eroded integrity of judicial process. Court abused its discretion by allowing State to introduce unlimited other crimes evidence as proof of Defendant's "mental state". (O'BRIEN and LYTTON, concurring.)
Illinois Appellate Court
Criminal Court
Impeachment