People v. Curry

Illinois Appellate Court
Criminal Court
Speedy Trial
Citation
Case Number: 
2020 IL App (2d) 180148
Decision Date: 
Thursday, September 10, 2020
District: 
2d Dist.
Division/County: 
McHenry Co.
Holding: 
Affirmed.
Justice: 
BRENNAN

Defendant was convicted of criminal sexual assault. Court did not abuse its discretion in granting State's section 103-5(c) motion for a continuance based on its findings that State exercised due diligence in attempting to obtain material DNA testing. Court did not abuse its discretion in granting State's motion in limine and admitting Facebook records as self-authenticating documents under Illinois Rule of Evidence 902(11). State submitted written certification of a qualified person from Facebook, providing that records were made and kept by Facebook in course of its regularly conducted activity and as part of its regular business practice. Court did not abuse its discretion in admitting content of the Facebook messages to victim which was properly authenticated by circumstantial evidence showing that Defendant was the author.(JORGENSEN and BRIDGES, concurring.)