People v. Chatman

Summary

The Illinois Supreme Court held that the forfeiture-by-wrongdoing hearsay exception requires the State to prove both the witness's unavailability and reasonable, good-faith efforts to procure the witness's attendance by a preponderance of the evidence. The court further held that the State satisfied that burden through repeated investigative efforts to locate the missing witness, whose disappearance followed threats associated with the defendant. Because the statements were properly admitted, the court did not reach the defendant's separate confrontation-clause and harmless-error arguments.