The People of the State of Illinois, Appellee v. Michael Glasper, Appellant

Summary

The Illinois Supreme Court affirmed Michael Glasper's convictions for first degree murder and attempted first degree murder, holding that the trial court's refusal—despite a defense request—to ask the Rule 431(b)(4)/Zehr voir dire question about bias against a non-testifying defendant was error but not structural error, and was harmless beyond a reasonable doubt given overwhelming evidence including three admissions, eyewitness identification, and ballistics. The court further held that most of the State's challenged rebuttal remarks were invited or proper, that two remarks (the foreperson instruction and the jury-service comparison) were improper but forfeited and not plain error, and that counsel's failure to object caused no Strickland prejudice. Justice Burke, joined by Justice Freeman, dissented, contending that Zehr itself held this voir dire failure to be prejudicial error requiring reversal and that harmless-error analysis is therefore inapplicable.