People v. Harding

PRESIDING JUSTICE MURPHY,

dissenting:

I respectfully dissent from the majority opinion. I concur with the majority that the instant case presents a strong argument for the addition of child abduction to the list of offenses for which evidence to prove propensity is allowed. 725 ILCS 5/115 — 7.3 (West 2002). I also agree with the majority that the instant matter presents a difficult question. However, I cannot conclude that the prejudicial effect of the other crimes evidence substantially outweighs its probative value such that the trial court’s conclusion was a clear abuse of its discretion. People v. Placek, 184 Ill. 2d 370, 385 (1998).

The majority points to Placek for the proposition that the prosecution was required to prove the other-crimes evidence was related to the charged offense and that the State’s statement of purpose or jury instructions cannot overcome a failure of this proof. Placek, 184 Ill. 2d at 386-89. It finds that it failed to meet even the minimal standard from People v. lllgen, 145 Ill. 2d 353, 373 (1991), that there must be “general areas of similarity” between the charged crime and prior crimes. The majority also points to cases that allowed other crimes evidence because the allegations involved the same manner of attack and similar victim (People v. Luczak, 306 Ill. App. 3d 319, 324-25 (1999); People v. Wilson, 214 Ill. 2d 127, 141 (2005); People v. Harris, 297 Ill. App. 3d 1073, 1086 (1998)) and agrees with defendant that his prior attacks are not similar enough to provide probative value. It concludes that defendant’s attacks on adult women by force offer little or no insight on his intent in this case and there is no authority permitting other-crimes evidence based on such broad generalities.

While we are unable to find clear precedent to permit the evidence based on the similarities here, I also have been unable to find clear precedent to reverse the trial court’s finding that evidence of extensive sexual deviancy may be used to prove intent. Defendant’s prior offenses involved attacks on adult women at night and the instant matter involves children during daytime; however, I believe the State’s argument that defendant’s background of extensive sexual deviancy counters his claim that his intent was simply to give the girls, whom he did not know, a ride. Certainly, this evidence could be used to prove propensity to commit this crime and the potential prejudicial effect was great, but the probative value of proving defendant’s intent is also great.

The trial court obviously gave this issue great consideration. It concluded that the convictions would be allowed to show “intent, absence of mistake, accident or innocent frame of mind and unlawful purpose.” The trial court admitted that the convictions could be considered remote, but opined that the probative value outweighed the prejudicial effect. Considering the evidence presented to the trial court, I believe that the trial court did not clearly abuse its discretion. Ultimately, the probative value of the other crimes evidence to defendant’s intent and absence of mistake was not substantially outweighed by the prejudicial effect of introducing that evidence and I would affirm defendant’s convictions.