State v. Brown
Annotate this CaseAfter a jury trial, Defendant was convicted of aggravated indecent liberties with a child under the age of fourteen and lewd and lascivious behavior in the presence of a person under the age of sixteen. Defendant was sentenced to life imprisonment, and the court imposed a term of lifetime postrelease supervision. The Supreme Court affirmed Defendant's convictions, vacated the imposition of lifetime postrelease supervision, and otherwise affirmed Defendant's sentence, holding (1) a statute, and any instruction that incorporates it, must list distinct alternatives for a material element of the crime in order to qualify for an alternative means analysis and application of the super-sufficiency requirement; (2) accordingly, Defendant's jury was not presented with alternative means on the charges against him; (3) the trial court did not err in allowing the State to reopen its case-in-chief to present evidence of Defendant's age; (4) the prosecutor committed misconduct, but the misconduct was harmless; and (5) the trial court erred in imposing lifetime postrelease supervision.
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