The People of the State of Illinois, Appellant v. John Naylor, Appellee

Summary

The Illinois Supreme Court affirmed the appellate court's reversal of the defendant's convictions for heroin possession with intent to deliver and delivery, holding that the 10-year time limit on impeaching a witness with a prior conviction runs from the date of conviction or release from confinement, whichever is later, to the date of trial — not the date of the charged offense. Because the 1990 aggravated battery conviction was nearly 14 years old at the 2004 bench trial, its admission was error; although the issue was procedurally forfeited, the court excused the default under the closely balanced prong of the plain-error doctrine because the trial turned entirely on credibility, and it found the evidence sufficient so that retrial is not doubly barred. Chief Justice Thomas, joined by Justices Garman and Karmeier, dissented: agreeing on the time-limit calculation, he would have held the error harmless because the trial court disbelieved the defendant for his repeated lack of recall, not because of the stale conviction.