Case Law People v. Logan

People v. Logan

Document Cited Authorities (29) Cited in Related

Appeal from the Appellate Court for the Fourth District; heard in that court on appeal from the Circuit Court of Macon County, the Hon. Thomas E. Griffith, Judge, presiding.

James E. Chadd, State Appellate Defender, Douglas R. Hoff, Deputy Defender, and Gilbert C. Lenz, Assistant Appellate Defender, of the Office of the State Appellate Defender, of Chicago, for appellant.

Kwame Raoul, Attorney General, of Springfield (Jane Elinor Notz, Solicitor General, and Katherine M. Doersch and Joshua M. Schneider, Assistant Attorneys General, of Chicago, of counsel), for the People.

OPINION

JUSTICE CUNNINGHAM delivered the judgment of the court, with opinion.

¶ 1 Following a jury trial in the circuit court of Macon County, the defendant, Jessica Logan, was convicted of the first degree murder of her 19-month-old son, J.C., and sentenced to 33 years in prison. Prior to trial, Logan filed a motion to suppress a video of a reenactment of J.C.’s death on the ground that the police should have admonished her under Miranda v. Arizona, 384 U.S. 436, 86 S.Ct. 1602, 16 L.Ed.2d 694 (1966). The trial court denied the motion to suppress, and the video was admitted into evidence and published to the jury during the State’s case-in-chief. The appellate court affirmed the trial court’s judgment, holding that the reenactment was not custodial. 2022 IL App (4th) 210492, ¶ 83, 461 Ill.Dec. 264, 203 N.E.3d 418. For the reasons that follow, we affirm the judgment of the appellate court, but for a different reason than that upon which the appellate court relied.

¶ 2 BACKGROUND

¶ 3 On November 25, 2019, the State charged Logan by information with three counts of first degree murder. The information alleged that on or between October 6 and 7, 2019, Logan knowingly asphyxiated J.C., thereby causing his death. See 720 ILCS 5/9-1(a)(1), (2) (West 2018).

¶ 4 Prior to trial, Logan filed a motion to suppress an October 17, 2019, video recording of her reenactment of her discovery of J.C.’s body. In the motion, Logan alleged that, following J.C.’s death and prior to her arrest on October 23, 2019, both the Department of Children and Family Services (DCFS) and detectives from the Decatur Police Department told her "that she would need to perform a reenactment of the events that transpired the night of J.C.’s death." She alleged that, "[o]n numerous occasions, she was told by DCFS investigator, Leandra Tate, that she would be required to participate in said reenactment." On the date of the reenactment, Logan arrived at her home with Hope Taylor (J.C.’s biological grandmother) and Logan’s four-year-old son. Upon their arrival, they were met by two DCFS investigators and three Decatur police officers. Logan alleged that all three police officers "were wearing vests indicating that they were police officers, they all wore badges around their necks indicating that they were police officers and they all had firearms that were in plain view."

¶ 5 Logan alleged that Taylor and Logan’s four-year-old son "were told that they would not be allowed to enter the home with [Logan] while the reenactment occurred and that they would need to remain outside." She alleged that no one told her at any point that the reenactment was voluntary or optional. She also alleged that she was not given Miranda warnings before or during the reenactment. Logan alleged that the detectives and DCFS investigators kept her at the apartment for well over an hour. She alleged that the "reenactment" portion of the encounter lasted only five or six minutes, while the remaining time was dedicated to asking her interrogatory questions unrelated to the reenactment. According to the motion, the police officers then asked Logan for consent to search her home, to which she agreed.

¶ 6 Logan alleged that the circumstances surrounding the reenactment constituted a custodial interrogation in violation of Miranda and her fifth amendment right against self-incrimination (U.S. Const., amend. V). On these grounds, Logan requested that the trial court "suppress any and all statements made by [Logan], including any and all video recordings of said reenactment/interview."

¶ 7 In response to the motion to suppress, the State argued that the reenactment and questioning on October 17, 2019, did not constitute a custodial interrogation because the circumstances showed that Logan was not in custody. According to the State, the reenactment bore no indicia of a formal arrest, and Logan voluntarily participated in the reenactment and never asked to leave the premises during the time in question. The State alleged, therefore, that Miranda warnings were not required.

¶ 8 On October 15, 2020, the trial court held a hearing on the motion to suppress. Prior to hearing testimony, the judge informed the parties that he had reviewed the pleadings and watched the video of the reenactment. The video was admitted into evidence. The defense then called Tate as its first witness.

¶ 9 Tate, a DCFS investigator in Decatur, Illinois, testified that she was assigned to investigate J.C.’s death. Tate testified that she met with Logan several times during her investigation. She testified that, in one of her conversations with Logan, she

"basically told [Logan], you know, we need to do a reenactment. We do that in all of our own child death cases. It will be a detective, at least myself and her, where it will be videotaped, and we need to do the reenactment so we can move forward on the investigation."

In response to defense counsel’s question as to whether Logan indicated that she did not want to do the reenactment, Tate gave the following testimony:

"A. I don’t recall her saying that she—I know that she was upset about that. She was worried about having to go back into the apartment, and emotionally she was not looking forward to that at all. She didn’t really want to do it, but there was no—there was no saying no. She didn’t refuse to do it, if that’s what you’re asking.

Q. Right. But she said she didn’t want to do it.

A. Yeah, in a way of saying I don’t really want to because I’m not—you know, I don’t really want to have to do this because, you know, I don’t want to have to go back in the apartment. Her son passed away there. She was very upset."

¶ 10 Tate testified that both she and Detective Matthews "set up" the reenactment but Matthews determined the time and place. Tate testified that she attended the reenactment in her official capacity as a DCFS investigator. On cross-examination by the State, Tate testified that Detective Matthews and another police officer questioned Logan during the reenactment. Tate said she did not recall whether she asked Logan any questions. She testified that she brought Ashley Moffett, another DCFS investigator, to the reenactment for "learning purposes" because Moffett had never been to a reenactment. In response to the State’s question asking whether Tate informed Logan of the reason for the reenactment, Tate testified:

"I told her that that’s just a process for DCFS and for criminal investigation that both parties would need the reenactment, you know, to be able to better understand what happened in her home that night, you know, so it was best to get this done so we can move forward in the investigation for both DCFS and for criminal."

¶ 11 Hope Taylor testified that she had known Logan for six or seven years, that she was a "mother figure" to her, and that Logan called her "Mom." Taylor testified that J.C. was her biological grandson. She testified that Logan had an individualized education plan (IEP) and attended special education classes during high school. According to Taylor, Logan’s IEP granted her special accommodations for learning, including unlimited time for taking tests and having test questions explained to her.

¶ 12 Taylor testified that, after J.C.’s death, Logan and her four-year-old son moved in with her. She stated that she and Logan returned to Logan’s apartment only once to pack up some belongings. Taylor testified that she was present for a conversation between Tate and Logan prior to the reenactment. She testified that Tate told Logan "that she would have to do it, and that is normal procedure in a child’s death." According to Taylor, Tate told them that Detective Matthews would set up the reenactment. Taylor testified that she accompanied Logan and her son to Logan’s former apartment on October 17, 2019. When they arrived, Taylor saw two or three police cars. Taylor testified that five law enforcement officers were present, including Tate, a DCFS trainee, Detective Matthews, and two other police officers. The police officers were wearing badges. Taylor testified that, when she attempted to follow the officers into the apartment, Detective Matthews "kind of just put his hand out and said, ‘I think it’s best to stay out.’ " Taylor said "okay" and stayed outside with her grandson. Taylor testified that she was outside for approximately 45 minutes before Logan and the others came out.

¶ 13 The defense then called Logan to the stand. She testified that she had had an IEP since elementary school because "I have a reading problem and I don’t comprehend what’s being said." Logan testified that, when Tate told her about the reenactment, she "didn’t feel like I had a choice" whether to attend it. She testified that, when Matthews called her to set up the date and time for the reenactment, he told her it was "standard procedure." She testified that she felt upset when she arrived at her former apartment because she did not want to "replay the moment" of her child’s death. On cross-examination, Logan testified that she unlocked the door of her apartment for the officers to enter it. She testified that she consented to a search of her apartment and her cell...

Experience vLex's unparalleled legal AI

Access millions of documents and let Vincent AI power your research, drafting, and document analysis — all in one platform.

Start a free trial

Start Your 3-day Free Trial of vLex and Vincent AI, Your Precision-Engineered Legal Assistant

  • Access comprehensive legal content with no limitations across vLex's unparalleled global legal database

  • Build stronger arguments with verified citations and CERT citator that tracks case history and precedential strength

  • Transform your legal research from hours to minutes with Vincent AI's intelligent search and analysis capabilities

  • Elevate your practice by focusing your expertise where it matters most while Vincent handles the heavy lifting

vLex

Start Your 3-day Free Trial of vLex and Vincent AI, Your Precision-Engineered Legal Assistant

  • Access comprehensive legal content with no limitations across vLex's unparalleled global legal database

  • Build stronger arguments with verified citations and CERT citator that tracks case history and precedential strength

  • Transform your legal research from hours to minutes with Vincent AI's intelligent search and analysis capabilities

  • Elevate your practice by focusing your expertise where it matters most while Vincent handles the heavy lifting

vLex

Start Your 3-day Free Trial of vLex and Vincent AI, Your Precision-Engineered Legal Assistant

  • Access comprehensive legal content with no limitations across vLex's unparalleled global legal database

  • Build stronger arguments with verified citations and CERT citator that tracks case history and precedential strength

  • Transform your legal research from hours to minutes with Vincent AI's intelligent search and analysis capabilities

  • Elevate your practice by focusing your expertise where it matters most while Vincent handles the heavy lifting

vLex

Start Your 3-day Free Trial of vLex and Vincent AI, Your Precision-Engineered Legal Assistant

  • Access comprehensive legal content with no limitations across vLex's unparalleled global legal database

  • Build stronger arguments with verified citations and CERT citator that tracks case history and precedential strength

  • Transform your legal research from hours to minutes with Vincent AI's intelligent search and analysis capabilities

  • Elevate your practice by focusing your expertise where it matters most while Vincent handles the heavy lifting

vLex