**Illinois Appellate Court / Criminal**

**Guilty but Mentally Ill** | 2d Dist. 

**People v. Lagrone, 2025 IL App (2d) 230543 (November 12, 2025)** Kane County (McLAREN) 

The court affirmed in part, modified in part, reversed in part, and remanded the case. The defendant was found guilty but mentally ill on six counts of home invasion, one count of armed violence, three counts of attempted aggravated kidnapping, one count of aggravated domestic battery, six counts of aggravated battery, and two counts of aggravated unlawful use of a weapon. On appeal, the defendant argued that the trial court's findings of "guilty but mentally ill" were against the manifest weight of the evidence. She also claimed she was denied effective assistance of counsel, that she could not be convicted of aggravated kidnapping of her own child, and that her conviction for aggravated domestic battery should be vacated under the one-act, one-crime doctrine. The appellate court affirmed the convictions for home invasion, armed violence, aggravated battery, and unlawful use of a weapon. The court modified the convictions for attempted aggravated kidnapping to the lesser-included offenses of unlawful restraint and attempted unlawful restraint, and remanded the case for resentencing. Finally, the appellate court reversed the convictions for aggravated domestic battery and aggravated battery and vacated the sentence imposed for aggravated domestic battery. (JORGENSEN and MULLEN, concurring)

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**Second Amendment** | 1st Dist. 

**People v. Redmond, 2025 IL App (1st) 231795 (November 12, 2025)** 2d Div./Cook County (McBRIDE) 

The court affirmed the decision. The defendant was convicted of second-degree murder and armed violence and sentenced to 22 years in prison. On direct appeal, the defendant argued that the armed violence statute violated the Second Amendment, both on its face and as applied. Additionally, she contended that the trial court erred in allowing the prosecutor and witnesses for the State to refer to the decedent as the “victim,” and in denying her request for a duty to retreat instruction in self-defense. The appellate court affirmed the trial court's judgment, finding that the armed violence statute does not conflict with the provisions of the Second Amendment because it does not regulate the possession of firearms by law-abiding citizens. The court also determined that the defendant was not prejudiced by the references to the decedent as the "victim," as these references were deemed insignificant and unobtrusive. Furthermore, the appellate court concluded that the trial judge did not err in instructing the jury. (VAN TINE and D.B. WALKER, concurring)ng)