Defendant Sentenced to 20 Years for Aggravated Battery of a Child

The Fifth District found sufficient evidence to support the conviction, upheld the admission of prior domestic violence evidence, and affirmed the 20-year sentence.

In People v. Steele, 2024 IL App (5th) 220533-U, the defendant, Tyrone Steele, was convicted of aggravated battery of a child, a Class X felony under Illinois law. He was sentenced to 20 years in the Illinois Department of Corrections, followed by three years of mandatory supervised release, with the sentence to be served at 85%.

Steele appealed his conviction and sentence, arguing that the State failed to prove him guilty beyond a reasonable doubt, that the circuit court improperly admitted evidence concerning prior acts of domestic violence, and that the court failed to properly consider mitigating factors at sentencing.

The Illinois Fifth District Appellate Court rejected all three arguments and affirmed the judgment of the Jefferson County Circuit Court.

Quick Answer

The appellate court held that the circumstantial evidence was sufficient to prove that Steele caused the child’s injuries and knew his conduct was practically certain to cause great bodily harm. The court also concluded that evidence of prior domestic violence was properly admitted and that Steele’s 20-year sentence was within the statutory range and did not constitute an abuse of discretion.

The decision was filed on January 16, 2024, as a Supreme Court Rule 23 order. It is therefore not precedential except in the limited circumstances permitted by Rule 23.

Background of the Case

L.S. was born prematurely on December 12, 2016. At the time of the events leading to the criminal case, L.S. was living with his mother, Abagail Adkins, and Steele, who was Adkins’s boyfriend and one of the child’s primary caregivers.

L.S. had significant medical needs after being born approximately 12 weeks premature. He had spent time in intensive care and required follow-up medical appointments after being discharged from the hospital.

On April 20, 2017, Adkins and a caseworker brought L.S. to Cardinal Glennon Children’s Hospital for a follow-up appointment. Medical personnel noticed that the infant’s head was enlarged and ordered additional testing.

An ultrasound and CT scan revealed bleeding between L.S.’s brain and skull. Doctors became concerned that the injuries could be the result of abuse. L.S. was admitted to the hospital for further testing.

Injuries Identified by Doctors

Rib Fractures

Fourteen fractures involving 12 different ribs.

Skull Fracture

A fracture was identified on the right side of the child’s skull.

Brain Injury

An injury affected the frontal area and corpus callosum of the brain.

Eye

Retinal Hemorrhaging

An eye specialist observed bleeding inside the retina.

L.S.’s doctors ordered additional MRI scans and X-rays. The imaging confirmed multiple rib fractures, a skull fracture, and a significant brain injury. An eye specialist also identified intraretinal hemorrhaging.

Dr. Timothy Kutz, the director of the Child Protection Division at Cardinal Glennon, testified that the injuries were consistent with abusive trauma. He explained that the nature and combination of the injuries could not be adequately explained by the accidental events described by Steele and Adkins.

Steele and Adkins were both charged with aggravated battery of a child under 720 ILCS 5/12-3.05(b)(1).

The Trial

Steele and Adkins initially proceeded through a joint bench trial. Dr. Kutz testified regarding L.S.’s medical history and the injuries discovered at the hospital.

Dr. Kutz explained that the injuries were not consistent with an ordinary fall or other accidental trauma. He testified that L.S. could not have caused the brain injury himself and that significant force was required to produce the injuries.

Steele provided several explanations for L.S.’s injuries. He said that L.S. had rolled off a couch, that he had performed CPR on the child when L.S. stopped breathing, and that hospital staff might have caused some of the injuries.

Adkins initially told investigators that L.S. had fallen off the couch. During a later interview, however, she described several incidents involving Steele and the child, including Steele throwing a bottle that struck L.S., moving the child forcefully over a couch, pressing hard on L.S.’s chest when he cried, and placing a pillow over the child’s face until he turned blue.

Adkins later recanted portions of those statements at trial. The circuit court nevertheless found her later statement to investigators credible and relied on the surrounding evidence in determining Steele’s guilt.

The Defense Position

The defense argued that the State could not establish who caused the injuries and that the injuries could have resulted from accidental events, CPR, or other circumstances. The defense also challenged the credibility of Adkins’s later statements to investigators.

After considering the evidence, the circuit court found Steele guilty of aggravated battery of a child.

The Appellate Court Found Sufficient Evidence

Steele argued on appeal that the evidence was almost entirely circumstantial and did not establish beyond a reasonable doubt that he, rather than someone else, caused L.S.’s injuries.

The Fifth District explained that circumstantial evidence can be sufficient to sustain a criminal conviction. The question on appeal is whether, viewing the evidence in the light most favorable to the prosecution, any rational trier of fact could have found the essential elements of the offense beyond a reasonable doubt.

The court determined that the evidence went well beyond establishing mere opportunity. Steele and Adkins were the child’s primary caregivers, there was no evidence that anyone else had injured L.S., and medical evidence established that the injuries were inflicted rather than accidental.

The appellate court also relied on Adkins’s statements describing prior incidents involving Steele and L.S. and the fact that Steele provided multiple explanations for the child’s injuries that did not account for the full extent of those injuries.

Why the Circumstantial Evidence Was Enough

The court emphasized that opportunity was only one part of the State’s case. The totality of the evidence included medical testimony, the severity and combination of the injuries, the defendant’s role as a primary caregiver, statements concerning the child’s treatment, and the absence of evidence that another person caused the injuries.

The State Also Proved the Required Mental State

Under 720 ILCS 5/12-3.05(b)(1), aggravated battery of a child requires proof that the defendant knowingly caused great bodily harm to a child under 13 years of age.

Steele argued that the State failed to prove that he knew his actions were practically certain to cause great bodily harm. The appellate court disagreed.

The Fifth District noted that knowledge is ordinarily established through circumstantial evidence rather than direct testimony. The court considered the severity of the injuries, the amount of force necessary to produce them, the substantial difference in size and strength between an adult and a four-month-old infant, and evidence that Steele had pressed hard on L.S.’s chest.

The court also considered Steele’s varying explanations concerning how the injuries occurred. Taken together, the evidence permitted the trier of fact to conclude that Steele knew his conduct was practically certain to cause great bodily harm.

Prior Domestic Violence Evidence Was Admitted

The State sought to introduce evidence of prior domestic violence involving Steele and Adkins. The circuit court ultimately allowed evidence concerning three prior incidents, although Steele challenged two of them on appeal.

The first challenged incident occurred when Adkins was attempting to place L.S. in a vehicle. After an argument, Steele followed her outside, pushed her to the ground, and swung at her. The circuit court allowed evidence of that incident because L.S. was present and nearby.

The second incident occurred while Adkins was five months pregnant with L.S. Steele knocked her to the ground. The circuit court permitted the State to introduce the incident after requiring the State to establish that Adkins was visibly pregnant or that Steele knew she was pregnant.

The State relied on 725 ILCS 5/115-7.4, which addresses the admissibility of evidence of domestic violence in criminal cases.

Why the Prior Acts Mattered

The State argued that the prior incidents were relevant to Steele’s motive and intent and helped rebut his claim that L.S.’s injuries were accidental. The court also considered the timing of the incidents and their relationship to the events involving L.S.

The Defense Forfeited Its Challenge to the Prior Acts

The appellate court first determined that Steele had failed to preserve this evidentiary issue for ordinary review. Although he objected to the evidence during the motion in limine hearing, he did not include the issue in his posttrial motion.

Illinois law generally requires a defendant to raise an evidentiary objection at trial or in a motion in limine and then include the issue in a posttrial motion in order to preserve it for appeal.

Because Steele failed to do so, the Fifth District held that he had forfeited the claim. The court nevertheless considered his request for plain-error review.

The court concluded that the circuit court did not abuse its discretion by admitting the evidence. The prior incidents were relatively close in time to the charged conduct and were relevant to motive and intent. The fact that the earlier domestic violence was directed at Adkins rather than L.S. did not automatically make it irrelevant.

Because the appellate court found no clear or obvious error in admitting the evidence, there was no basis for plain-error relief.

The 20-Year Sentence Was Also Affirmed

Steele’s final argument concerned sentencing. He argued that the circuit court failed to adequately consider his age and lack of criminal history as mitigating factors.

At the time of the offense, Steele was 19 years old. His attorney argued that his youth, lack of criminal history, and rehabilitative potential supported a lower sentence.

The circuit court considered several aggravating factors, including the need to deter others, L.S.’s young age and helplessness, the severity of the injuries, and Steele’s parental relationship with the child. The court also considered Steele’s lack of prior criminal history as a mitigating factor.

Under the law applicable to the offense, aggravated battery of a child carried a sentencing range of 6 to 30 years, with the sentence to be served at 85%. Steele received 20 years, which was 10 years below the statutory maximum.

Sentencing Result

Years

Prison sentence imposed

85%

Service Requirement

Sentence to be served at 85%

Years MSR

Mandatory supervised release

The Fifth District held that the sentence was within the statutory range and that the record showed the circuit court considered the relevant aggravating and mitigating factors. The appellate court declined to substitute its judgment for that of the trial judge.

The court also distinguished Steele’s age from cases involving juvenile defendants. Steele was 19 at the time of the offense and therefore was an adult. His relative youth, standing alone, did not make a sentence above the statutory minimum excessive.

What People v. Steele Means for Illinois Criminal Cases

People v. Steele, 2024 IL App (5th) 220533-U illustrates how Illinois appellate courts evaluate a conviction based on circumstantial evidence. A conviction does not require direct eyewitness testimony when the totality of the evidence permits a rational trier of fact to find every element of the offense beyond a reasonable doubt.

The case also demonstrates the importance of preserving evidentiary objections. Steele objected to the prior domestic violence evidence before trial, but because he did not include the issue in his posttrial motion, the appellate court treated the claim as forfeited and reviewed it only under the plain-error doctrine.

Finally, the decision shows that an Illinois trial court is presumed to have considered relevant sentencing factors. An appellate court generally will not reweigh those factors when the sentence falls within the statutory range unless the record demonstrates an abuse of discretion.

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If you have been charged with a serious criminal offense, call the Champaign criminal defense attorneys at Patel Law, P.C. at 217-384-1111 to schedule a consultation and discuss your defense options.