People v. Axtell

Defendant was convicted, after bench trial, of 1st-degree murder of his live-in girlfriend. Court properly concluded that victim had suffered "great bodily harm" from the 2nd blow, after Defendant having knocked her unconscious and bruised her, and this conclusion amply supported crucial finding that State proved Defendant's guilty knowledge with the fatal 3rd blow. Court properly admitted victim's statement to her son that Defendant was going to kill her, as it implicitly related to Defendant's very recent past conduct, and remark related to the startling event that preceded it.(HUTCHINSON and SPENCER, concurring.)