The Illinois Supreme Court unanimously affirmed a trial court's use of standard pattern jury instructions in a criminal case involving threats against a public official, resolving an appellate question about proper jury instruction procedures under Illinois law.
The November 20, 2025 decision in *People v. Williams* (2025 IL 130779) addressed whether the Kendall County circuit court committed plain error when it provided Illinois Pattern Jury Instructions, Criminal, Nos. 11.49 and 11.50 to the jury during defendant Isaiah J. Williams' trial for threatening a public official.
Justice Cunningham delivered the court's opinion, with Chief Justice Neville and Justices Theis, Overstreet, Holder White, Rochford, and O'Brien all concurring in the unanimous judgment.
The case originated from an incident on April 29, 2021, when Kendall County Sheriff's Deputy Nicholas Albarran responded to a domestic battery call at the residence of Williams and his girlfriend, Teresa Sanchez. After speaking with Sanchez, Deputy Albarran arrested Williams for domestic battery.
During his arrest and subsequent transportation to the Kendall County Jail, Williams made repeated threats against Deputy Albarran. These threats formed the basis for criminal charges filed against Williams.
The State of Illinois charged Williams with one count of aggravated domestic battery and one count of threatening a public official under section 12-9 of the Criminal Code of 2012. The threatening public official charge specifically falls under Illinois statute 720 ILCS 5/12-9, which criminalizes threats made against public officials in the performance of their duties.
At trial, the central legal question emerged regarding which jury instructions should be provided to help jurors understand the elements required to convict someone of threatening a public official. The trial court opted to use Illinois Pattern Jury Instructions, Criminal, Nos. 11.49 and 11.50, which were approved on May 2, 2014.
These pattern jury instructions provide standardized language that courts across Illinois use to explain legal concepts to juries in criminal cases. Pattern instructions are developed to ensure consistency in how legal principles are communicated to juries and to reduce the likelihood of reversible error due to improper or confusing jury instructions.
The defendant appealed his conviction, arguing that the trial court committed plain error by tendering these specific pattern jury instructions to the jury. Under Illinois law, plain error analysis applies when a defendant fails to object to jury instructions at trial but later claims on appeal that the instructions were fundamentally flawed.
The Illinois Appellate Court for the Second District initially heard the case and ruled in favor of the State. In their 2024 decision (*People v. Williams*, 2024 IL App (2d) 230268-U), the appellate court held that the pattern jury instructions correctly set forth the applicable law for threatening public official charges and therefore the Kendall County circuit court did not err in providing them to the jury.
The case then proceeded to the Illinois Supreme Court, where Williams continued to challenge the propriety of the jury instructions. The high court's review focused on whether the pattern instructions accurately reflected Illinois law regarding the elements necessary to prove a threatening public official charge.
Pattern jury instructions serve several important functions in the criminal justice system. They provide uniformity across different courts and judges, help ensure that juries receive accurate statements of law, and reduce the potential for reversible error that could result from improper or confusing instructions.
The threatening public official statute under Illinois law requires the State to prove specific elements, including that the defendant made a threat, that the threat was directed at a public official, and that the threat was made in connection with the official's performance of their duties. Proper jury instructions help ensure that juries understand these required elements and apply them correctly to the facts presented at trial.
The Illinois Supreme Court's unanimous affirmance of the appellate court's decision provides important guidance for trial courts across the state regarding the continued validity and appropriateness of Pattern Jury Instructions 11.49 and 11.50 for threatening public official cases.
This decision reinforces the reliability of Illinois' standardized pattern jury instruction system and confirms that courts may continue using these specific instructions when defendants are charged with threatening public officials. The unanimous nature of the decision suggests broad agreement among the justices that these instructions adequately and accurately convey the legal standards to juries.
For practitioners handling similar cases, the decision provides clarity that challenges to these pattern instructions on plain error grounds are unlikely to succeed when the instructions accurately state the law. The ruling also demonstrates the Illinois Supreme Court's continued support for the pattern instruction system as a tool for promoting consistency and accuracy in jury trials across the state.
The case represents another example of Illinois appellate courts working to ensure that criminal defendants receive fair trials while also maintaining the integrity of standardized legal procedures designed to promote consistent application of the law.