People v. Richmond

5 Citing cases

  1. People v. Thompkins

    181 Ill. 2d 1 (Ill. 1998)   Cited 60 times

    The State's arguments in support of the circuit court's actions are not persuasive. The State submits that defendant's offers of proof are not relevant and thus were properly excluded. In support, the State cites People v. Richmond, 201 Ill. App.3d 130 (1990), which holds that a refusal to take an offer of proof is not error where the record reveals that the suggested testimony is not relevant. Relevant evidence is evidence having any tendency to make the existence of any fact of consequence to the action's determination more or less probable than it would be without the evidence. People v. Hope, 168 Ill.2d 1, 23 (1995).

  2. State v. Lange

    531 N.W.2d 108 (Iowa 1995)   Cited 46 times
    Holding that Iowa's drug tax is not a criminal penalty and, consequently, does not implicate the Double Jeopardy Clause

    The district court likewise here committed no reversible error either in its ruling or in its refusal to permit the defendant to make an offer of proof as to this witness. Compare People v. Richmond, 201 Ill. App.3d 130, 136-40, 147 Ill.Dec. 302, 307-09, 559 N.E.2d 302, 307-09 (1990) (trial court properly refused to allow defense counsel in murder prosecution to make an offer of proof regarding witness seeking "crimestopper" money in another case, where evidence of compensation paid witness in prior case had no relevancy to present prosecution and was too remote to act reliably as impeachment). In addition, evidence of Lange's guilt was overwhelming, rendering harmless any error arising from the district court's refusal to permit Lange to make these offers of proof.

  3. People v. Beard

    273 Ill. App. 3d 135 (Ill. App. Ct. 1995)   Cited 6 times

    In order to preserve an alleged error for review, a defendant must object at trial and include the issue in a written post-trial motion. ( People v. Enoch (1988), 122 Ill.2d 176, 186, 522 N.E.2d 1124, 1130; People v. Richmond (1990), 201 Ill. App.3d 130, 134, 559 N.E.2d 302, 305.) Therefore, we must analyze this issue under the doctrine of plain error.

  4. People v. Gillis

    883 P.2d 554 (Colo. App. 1994)   Cited 19 times
    Approving introduction of evidence of prior misdemeanor convictions under CRE 608(b) despite provisions of § 13-90-101

    Accordingly, defendant's proposed testimony was not relevant to his defense. We therefore conclude that although the trial court should have allowed defendant's offer of proof, no reversible error occurred under the circumstances presented here. See Parliament Insurance Co. v. Hanson, 676 F.2d 1069 (5th Cir.), rehearing denied, 688 F.2d 839 (5th Cir. 1982) (no offer of proof necessary when offering party's position was adequately stated at trial and the record was susceptible to proper appellate review); People v. Richmond, 559 N.E.2d 302 (Ill.App. 1990) (court's refusal to allow defense counsel to make offer of proof not reversible error when the nature of the evidence to be elicited was clear, and the evidence was not relevant). Even if we were to conclude that the trial court erred in refusing to allow the offer of proof, any such error would have been harmless under the circumstances here, especially in light of the overwhelming evidence of defendant's guilt.

  5. People v. Stewart

    594 N.E.2d 429 (Ill. App. Ct. 1992)   Cited 5 times

    • 1 Trial courts are required to permit counsel to make offers of proof, and a refusal to permit the offer is error. However, the court's refusal of the offer is not error if the suggested testimony is not relevant. ( People v. Richmond (1990), 201 Ill. App.3d 130, 137, 559 N.E.2d 302, 307.) Here, the State originally cited its willingness to offer proof that another circuit court had recently allowed the use of bloodhound evidence at trial.