People v. Chatman

Defendant was found guilty of felony murder and appealed, arguing that the trial court erred when it allowed statements into evidence that were made by an unavailable witness. Defendant argued that the State was required to demonstrate good faith efforts to secure the witness at trial but failed to do so. The supreme court affirmed, finding that the trial court did not abuse its discretion in allowing admission of the statements where the evidence showed, among other things, that the investigating officer utilized the information available to him to try to find the missing witness including visiting multiple addresses in different counties and states. (THEIS, NEVILLE, OVERSTREET, CUNNINGHAM, ROCHFORD, and O’BRIEN, concurring)