{
  "id": 5215773,
  "name": "THE PEOPLE OF THE STATE OF ILLINOIS, Plaintiff-Appellee, v. STANLEY CARTER LIGGINS, Defendant-Appellant",
  "name_abbreviation": "People v. Liggins",
  "decision_date": "1992-05-29",
  "docket_number": "No. 3\u201491\u20140378",
  "first_page": "621",
  "last_page": "623",
  "citations": [
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  "court": {
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    "id": 8837,
    "name": "Illinois Appellate Court"
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    "name_long": "Illinois",
    "name": "Ill."
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    {
      "cite": "219 Ill. App. 3d 482",
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  "last_updated": "2023-07-14T21:04:36.221708+00:00",
  "provenance": {
    "date_added": "2019-08-29",
    "source": "Harvard",
    "batch": "2018"
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  "casebody": {
    "judges": [],
    "parties": [
      "THE PEOPLE OF THE STATE OF ILLINOIS, Plaintiff-Appellee, v. STANLEY CARTER LIGGINS, Defendant-Appellant."
    ],
    "opinions": [
      {
        "text": "JUSTICE STOUDER\ndelivered the opinion of the court:\nThe circuit court of Rock Island County found the defendant, Stanley Liggins, guilty of aggravated criminal sexual abuse and sentenced him to a seven-year term of imprisonment. The sole issue on appeal is whether the trial court erred when it decided the case without allowing the defendant the opportunity to present closing argument.\nThe evidence adduced at trial established that on August 3, 1990, A.S. and a friend, T.S., were playing when they decided to get a refreshment. The pair then proceeded to Brenda Adams\u2019 apartment to get some \u201cKool Aid.\u201d The defendant was in the Adams apartment. A.S. and T.S. made some Kool Aid and went out onto the back steps to drink it when A.S. spilled some of her drink on her leg. The girls then went back into the Adams apartment, where the defendant brought A.S. a washcloth to wipe the spill.\nAt this point, the defendant told T.S. to leave the apartment. He then washed A.S.\u2019s left leg, and, despite her protest, her right leg. He next pulled A.S.\u2019s swimsuit to one side and began wiping her \u201cprivate part\u201d; her vagina. A.S. then screamed and ran out the door. Thinking the defendant was chasing her, A.S. ran to the nearby apartment of Charlotte Ledbetter and reported to her what occurred.\nT.S. and Charlotte Ledbetter also testified. Their testimony substantially corroborates what A.S. testified to earlier.\nAfter the State rested, the defense moved for a directed verdict and extensively argued the alleged weakness of the State\u2019s case. When the trial court denied the motion, the defendant took to the witness stand.\nThe defendant testified that he was living in the Adams apartment with the Adams family. He specifically recalls when A.S. and T.S. came over for Kool Aid and when A.S. accidentally spilled Kool Aid on her leg. According to the defendant, he went to the bathroom to retrieve a washcloth for A.S. After giving A.S. the washcloth, he went back to the bathroom. After spending several minutes in the bathroom, the defendant went back to the dining room. At this point, the defendant further explained, A.S. screamed, threw the towel, and ran for the door. He claims he did not touch A.S. at any time.\nFollowing the defendant\u2019s testimony, the State produced a prior conviction of defendant.\nAfter the State indicated it had no further evidence, the trial transcript indicates the cause proceeded as follows:\n\u201cTHE COURT: Anything further?\nMR. STENGEL (prosecutor): No, your honor.\nTHE COURT: Then I am ready to rule. I don\u2019t believe I need closing argument.\nMR. SCOVTL (defense counsel): We would renew our motion for a verdict at the close of the evidence.\nTHE COURT: Your motion is denied. Any other motions?\nMR. STENGEL: No.\nMR. SCOVIL: No.\u201d\nThe court then ruled in the case. The trial court discussed the evidence and found the defendant guilty.\nAccording to the State, under these circumstances it wasn\u2019t error for the trial court to deny the opportunity to present closing argument. The State points out the defendant did not object when the trial court stated that it felt closing arguments were unnecessary in this case.\nThe right to closing argument can be waived. (People v. Riley (1991), 219 Ill. App. 3d 482, 579 N.E.2d 1008.) If a trial court in a bench trial enters its findings directly after the presentation of evidence, defense counsel has the right to object and be given the opportunity to present a closing argument. (People v. Daniels (1977), 51 Ill. App. 3d 545, 366 N.E.2d 1085.) Where no attempt is made to seek closing argument, it cannot be said that a party was denied the opportunity to present a closing argument. People v. Coleman (1991), 212 Ill. App. 3d 997, 571 N.E.2d 1035.\nThe record in the instant case reveals the trial court began to announce its findings immediately following the close of the defendant\u2019s case. Defendant did not, however, request an opportunity to make a closing argument and did not object to the trial court\u2019s actions. Therefore, under these circumstances, we hold the defendant was not deprived of the right to present closing argument.\nFor these reasons, we affirm the judgment of the circuit court of Rock Island County.\nAffirmed.\nMcCUSKEY and HAASE, JJ., concur.",
        "type": "majority",
        "author": "JUSTICE STOUDER"
      }
    ],
    "attorneys": [
      "Verlin R. Meinz, of State Appellate Defender\u2019s Office, of Ottawa, for appellant.",
      "Marshall E. Douglas, State\u2019s Attorney, of Rock Island (John X. Breslin and Terry A. Mertel, both of State\u2019s Attorneys Appellate Prosecutor\u2019s Office, of counsel), for the People."
    ],
    "corrections": "",
    "head_matter": "THE PEOPLE OF THE STATE OF ILLINOIS, Plaintiff-Appellee, v. STANLEY CARTER LIGGINS, Defendant-Appellant.\nThird District\nNo. 3\u201491\u20140378\nOpinion filed May 29, 1992.\nVerlin R. Meinz, of State Appellate Defender\u2019s Office, of Ottawa, for appellant.\nMarshall E. Douglas, State\u2019s Attorney, of Rock Island (John X. Breslin and Terry A. Mertel, both of State\u2019s Attorneys Appellate Prosecutor\u2019s Office, of counsel), for the People."
  },
  "file_name": "0621-01",
  "first_page_order": 643,
  "last_page_order": 645
}