People v. Talley

Defendant was convicted of aggravated criminal sexual assault and armed robbery and sentenced to consecutive terms of 45 years and 35 years in prison. Defendant appealed, arguing that the appellate court should remand for a new Batson hearing because the procedures used during the initial hearing were inadequate and resulted in an insufficient record to review the merits of his challenge. The appellate court affirmed, finding that the defendant did not meet his burden of providing that the procedures used by the trial court were inadequate under the plain-error doctrine. (DeARMOND and ZENOFF, concurring)