People v. Hartfield
Annotate this Case
Defendant fired a gun at four police officers and was convicted of armed robbery and four counts of aggravated discharge of a firearm. The appellate court reversed in part after finding no speedy trial or public trial violation and no reversible error on a jury instruction issue. The appellate court vacated three of the aggravated discharge convictions, finding that the state had effectively prosecuted the defendant based on his firing a single shot at four officers.
The Illinois Supreme Court remanded, agreeing with the appellate court. As to the speedy trial claim, the defendant did not demand trial in the statutorily directed manner and is considered to have agreed to the first continuance. There was no abuse of discretion in granting the state’s first motion for continuance. Counsel was not ineffective on that issue. The erroneous and contradictory jury instructions, however, require reversal and retrial. On retrial, the unit of prosecution issue is likely to recur. Where the legislature can, but does not, define the unit of prosecution, the doctrine of lenity applies. The offense of aggravated discharge of a firearm does not clearly define the unit of prosecution, so a single discharge in the direction of multiple police officers can sustain only one conviction.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.