The Illinois Supreme Court issued a ruling Thursday that clarifies a critical procedural question in criminal trials, holding that trial courts must decide defendants' mid-trial motions for directed verdict before allowing the defense to present evidence.
In *People v. Johnson* (2025 IL 130447), the court addressed whether trial courts have discretion in the timing of ruling on directed verdict motions made during trial. Justice O'Brien delivered the judgment of the court, with Chief Justice Neville and Justices Overstreet and Holder White concurring. Justice Cunningham filed a special concurrence joined by Justices Theis and Rochford.
The case arose from defendant Devin Johnson's conviction for attempted first degree murder and aggravated battery with a firearm in the shooting of Kelvin Bell. During Johnson's jury trial in Rock Island County circuit court, the defendant made a mid-trial motion for directed verdict that the trial court did not immediately rule upon before proceeding to the defense's case.
The Fourth District Appellate Court had sidestepped the substantive procedural question, instead finding that Johnson had forfeited appellate review of the issue. The appellate court affirmed Johnson's conviction and sentence without addressing whether trial courts must rule on such motions before advancing to defense evidence.
The Supreme Court disagreed with the appellate court's forfeiture finding and reached the merits of the procedural question. "At issue before this court is whether a trial court must decide a defendant's midtrial motion for a directed verdict before proceeding to the defense's evidence," the court wrote in its opinion filed Oct. 31, 2025.
The court held that trial courts lack discretion in this timing question and must rule on directed verdict motions before allowing the defense to present its case. This ruling establishes a clear procedural requirement for criminal trials throughout Illinois and removes any ambiguity about when such motions must be addressed.
Despite finding that the trial court committed procedural error by failing to rule on Johnson's motion before proceeding to defense evidence, the Supreme Court determined this error did not warrant reversal. The court applied the plain error standard, which allows appellate courts to address unpreserved errors only in limited circumstances.
Under Illinois law, plain error review applies when either the evidence is closely balanced or the error is so serious it affected the fairness of the defendant's trial and challenged the integrity of the judicial process. The court found neither prong of the plain error test was satisfied in Johnson's case.
"We find the evidence is not closely balanced, and we find that defendant failed to satisfy his burden in establishing second prong plain error," the court wrote. This finding indicates the evidence against Johnson was sufficiently strong that the procedural error did not affect the outcome of his trial.
The ruling provides important guidance for trial courts across Illinois on criminal procedure while also demonstrating the high bar defendants face when seeking reversal based on procedural errors. Trial courts must now ensure they rule on directed verdict motions immediately when made during trial, rather than deferring such decisions.
Directed verdict motions, also known as motions for judgment of acquittal, allow defendants to argue that the prosecution has failed to present sufficient evidence to support a conviction. These motions test whether a reasonable jury could find guilt beyond a reasonable doubt based on the evidence presented.
The timing of when courts rule on these motions can be strategically important for both prosecution and defense. Defendants may prefer immediate rulings to potentially end proceedings early if successful, while prosecutors may seek to present their full case before such motions are decided.
The Supreme Court's ruling eliminates this strategic consideration by requiring immediate decisions. Trial courts can no longer defer ruling on directed verdict motions until after hearing defense evidence.
Johnson was charged with attempted first degree murder under 720 ILCS 5/8-4(a), (c)(1)(D) and aggravated battery with a firearm under section 12-3.05(e)(1) of the Illinois Criminal Code. The charges stemmed from the shooting of Kelvin Bell, though the court's opinion does not detail the specific circumstances of the incident.
The case demonstrates how procedural rules in criminal trials can significantly impact how cases proceed, even when the ultimate outcome remains unchanged. While Johnson's conviction was affirmed, the Supreme Court's ruling will affect how similar motions are handled in future criminal trials throughout Illinois.
The decision also illustrates the careful balance appellate courts must strike between ensuring proper procedure and avoiding unnecessary reversals when errors do not affect trial outcomes. The court's plain error analysis shows that procedural mistakes, while requiring correction for future cases, do not automatically result in overturned convictions when the evidence of guilt is substantial.
This ruling joins a body of Illinois Supreme Court decisions that provide procedural guidance for trial courts while maintaining focus on substantive justice in criminal cases.