People v. Stahl 2014 IL 115804


Appellate citation: 2013 IL App (5th) 110385.


††††††††††† JUSTICE KARMEIER delivered the judgment of the court, with opinion.


††††† Chief Justice Garman and Justices Freeman, Thomas, Kilbride, Burke, and Theis concurred in the judgment and opinion.


††††††††††† In this St. Clair County case, the defendant was charged with home invasion and aggravated unlawful restraint after he broke into his estranged wifeís home in 2009. She had filed for divorce and had obtained an order of protection against him. At the conclusion of the events which ensued, the defendant shot himself in the face, but survived. However, due to brain damage from his self-inflicted gunshot wound, he could not remember any of the events surrounding the incidents leading to the offenses charged.

††††††††††† After Stahlís indictment, his defense counsel filed a motion challenging his fitness for trial. Ultimately, the circuit court found that he was unfit and that it was not reasonably probable that he would be fit within one year. The State argued that this ruling was against the manifest weight of the evidence and appealed, claiming that amnesia related to the events surrounding the charges is not sufficient, in and of itself, to support a finding of unfitness. However, the appellate court affirmed the circuit courtís ruling and the State appealed again.

††††††††††† This issue is one of first impression before the Illinois Supreme Court. In this decision, the court disagreed with the proposition that amnesia as to the events surrounding the crime will always render a defendant unfit to stand trial, since fitness must be judged based on the totality of the circumstances.

††††††††††† Expert testimony had been given. It indicated that, in addition to amnesia, the defendant now suffered from short-term memory loss. Thus, he would be unable to track what happened in court from one day to the next, impacting his ability to communicate with counsel and assist in the defense. Because the totality of the circumstances must be considered in determining fitness, the supreme court held that, here, the circuit courtís finding was not against the manifest weight of the evidence. The appellate courtís affirmance of the circuit courtís finding of unfitness for trial was upheld.