Illinois Supreme Court
People v. Jackson
September 22, 2022463 Ill. Dec. 853
Summary
The court held that the circuit court clearly erred by polling only 11 of 12 jurors, but the defendant forfeited that error by failing to object and failing to raise it in his posttrial motion. The incomplete poll was a nonstructural trial error subject to prejudice-based review under the first prong of plain error, not structural error excusable under the second prong. The court therefore reversed the appellate court’s judgment, affirmed the circuit court’s judgment, and remanded for consideration of the defendant’s unaddressed sentencing arguments.