Summary
The Illinois Appellate Court, Third District, affirmed Anthony F. Maggio's convictions for two counts of first degree murder. The court held that the circuit court did not abuse its discretion by excluding evidence concerning an alternative suspect as remote and speculative, relying on the suspect's corroborated whereabouts and the forensic evidence linking Maggio to the crime scene. The court also addressed Maggio's reasonable-doubt and mistrial arguments arising from the jury's extended and initially nonunanimous deliberations.
Topics
Practice areas
Questions Presented
- Whether the circuit court abused its discretion by excluding evidence that Jordan Eaton was an alternative suspect because the evidence was remote, irrelevant, and speculative.
- Whether the State proved defendant guilty of two counts of first degree murder beyond a reasonable doubt despite lacking direct evidence placing defendant at the crime scene at the precise time of the murders.
- Whether the circuit court abused its discretion by denying a mistrial and directing the jury to continue deliberating after repeated statements that it had not reached a unanimous decision and one statement that deliberations had become heated.
Holdings
- The circuit court did not abuse its discretion by excluding evidence concerning Jordan Eaton as an alternative suspect because the proposed evidence was remote and speculative and had little probative value in relation to the murders.
- The evidence, viewed in the light most favorable to the State, was sufficient for a rational jury to find beyond a reasonable doubt that defendant committed both murders.
- The circuit court did not abuse its discretion by denying a mistrial and permitting the jury to continue deliberating after approximately ten hours, including an overnight recess.
Key quotations
“the appellate court decisions have generally found that remote, nonspecific, and speculative evidence that the crime could have been committed by another is properly excluded.” (¶ 26)
“This standard of review does not allow the reviewing court to substitute its judgment for that of the fact finder on questions involving the weight of the evidence or the credibility of the witnesses.” (¶ 31)
“Based on the foregoing, we cannot say the court abused its discretion by denying defendant’s motion for mistrial.” (¶ 35)
Factual background
Ashtin Eaton and her daughter, Hazel Bryant, were murdered in October 2020. Evidence at trial included defendant's DNA under Ashtin's fingernails, on her shirt neckline, and on a box cutter near her body; evidence of defendant's motive concerning child support and his relationship with Ashtin and Baliczek; and testimony that defendant offered to pay a coworker to make Ashtin disappear. Defendant sought to introduce evidence that Ashtin's ex-husband, Jordan Eaton, was an alternative suspect, but the trial court found that evidence remote and speculative. After approximately ten hours of first-day deliberations and repeated notes that the jury was not unanimous, the court denied a mistrial, recessed the jury overnight, and the jury returned unanimous guilty verdicts the next day.
Procedural history
The Will County circuit court denied defendant's motion in limine seeking to introduce evidence implicating Jordan Eaton as an alternative suspect, denied reconsideration, and conducted a jury trial. The jury found defendant guilty of two counts of first degree murder. The circuit court denied defendant's motion for a new trial and motion to reconsider his life sentence. The Appellate Court of Illinois affirmed.