People v. Patterson

Following a jury trial in the circuit court of Champaign County, defendant Ricky A. Patterson was convicted of first degree murder (720 ILCS 5/9—1(a)(1) (West 2002)), concealment of a homicidal death (720 ILCS 5/9—3.1(a) (2002)), and arson (720 ILCS 5/20—1(a) (West 2002)). Defendant was sentenced to 55 years in prison. On appeal, defendant argued, inter alia, that the circuit court erred in admitting the grand jury testimony of Migdalia Rivera, who declined to testify at trial. The appellate court held that, under Crawford v. Washington, 541 U.S. 36, 158 L. Ed. 2d 177, 124 S. Ct. 1354 (2004),…