The People of the State of Illinois, Appellant v. Angelo Thompson, Appellee

Summary

The Illinois Supreme Court held that although the trial court violated amended Supreme Court Rule 431(b) by never asking prospective jurors whether they understood and accepted that defendant was not required to present evidence, and by asking whether they understood but not whether they accepted the presumption of innocence, the violation is not structural error requiring automatic reversal. Because defendant neither objected at trial nor raised the issue in his posttrial motion, the claim was forfeited; the court declined to relax forfeiture under the Sprinkle doctrine, found neither plain-error prong satisfied absent evidence of actual jury bias, and refused to adopt a bright-line rule of reversal for Rule 431(b) violations. It accordingly reversed the appellate court's judgment and affirmed the conviction and one-year sentence. Justice Burke, dissenting, joined by Justice Freeman, would have held that the failure to ask the Zehr-mandated questions is necessarily plain error under stare decisis.