{ "id": 5573726, "name": "THE PEOPLE OF THE STATE OF ILLINOIS, Plaintiff-Appellee, v. LETORRIES CAUSEY, Defendant-Appellant; THE PEOPLE OF THE STATE OF ILLINOIS, Plaintiff-Appellee, v. NORMAN WALLACE, Defendant-Appellant", "name_abbreviation": "People v. Causey", "decision_date": "2003-06-27", "docket_number": "Nos. 1\u201401\u20141984, 1\u201401\u20142590 cons.", "first_page": "759", "last_page": "774", "citations": [ { "type": "official", "cite": "341 Ill. App. 3d 759" } ], "court": { "name_abbreviation": "Ill. App. Ct.", "id": 8837, "name": "Illinois Appellate Court" }, "jurisdiction": { "id": 29, "name_long": "Illinois", "name": "Ill." }, "cites_to": [ { "cite": "373 U.S. 83", "category": "reporters:federal", "reporter": "U.S.", "case_ids": [ 11716714 ], "weight": 3, "year": 1963, "opinion_index": 0, "case_paths": [ "/us/373/0083-01" ] }, { "cite": "761 N.E.2d 1199", "category": "reporters:state_regional", "reporter": "N.E.2d", "year": 2001, "pin_cites": [ { "page": "1210-11" } ], "opinion_index": 0 }, { "cite": "326 Ill. App. 3d 914", "category": "reporters:state", "reporter": "Ill. 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App. 3d", "case_ids": [ 486127 ], "year": 2002, "pin_cites": [ { "page": "992-93", "parenthetical": "consecutive sentences proper when defendant was convicted of home invasion, a Class X felony, and the victim's death occurred during the commission of that offense" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/333/0971-01" ] }, { "cite": "786 N.E.2d 195", "category": "reporters:state_regional", "reporter": "N.E.2d", "year": 2002, "opinion_index": 0 }, { "cite": "201 Ill. 2d 602", "category": "reporters:state", "reporter": "Ill. 2d", "year": 2002, "opinion_index": 0 }, { "cite": "768 N.E.2d 168", "category": "reporters:state_regional", "reporter": "N.E.2d", "year": 2002, "pin_cites": [ { "page": "173-77" } ], "opinion_index": 0 }, { "cite": "329 Ill. App. 3d 1", "category": "reporters:state", "reporter": "Ill. 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App. 3d", "case_ids": [ 927616 ], "year": 1995, "pin_cites": [ { "page": "762" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/276/0750-01" ] }, { "cite": "437 N.E.2d 625", "category": "reporters:state_regional", "reporter": "N.E.2d", "year": 1982, "pin_cites": [ { "page": "628", "parenthetical": "mandatory consecutive sentencing applies even when defendant is convicted on accountability theory" } ], "opinion_index": 0 }, { "cite": "91 Ill. 2d 260", "category": "reporters:state", "reporter": "Ill. 2d", "case_ids": [ 3092383 ], "year": 1982, "pin_cites": [ { "page": "265-66", "parenthetical": "mandatory consecutive sentencing applies even when defendant is convicted on accountability theory" } ], "opinion_index": 0, "case_paths": [ "/ill-2d/91/0260-01" ] }, { "cite": "728 N.E.2d 503", "category": "reporters:state_regional", "reporter": "N.E.2d", "year": 2000, "pin_cites": [ { "page": "507" } ], "opinion_index": 0 }, { "cite": "312 Ill. 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LETORRIES CAUSEY, Defendant-Appellant. \u2014 THE PEOPLE OF THE STATE OF ILLINOIS, Plaintiff-Appellee, v. NORMAN WALLACE, Defendant-Appellant." ], "opinions": [ { "text": "JUSTICE GALLAGHER\ndelivered the opinion of the court:\nFollowing simultaneous jury trials, defendants Letorries Causey and Norman Wallace were convicted of the first degree murder and armed robbery of Ricardo Epps. The trial court sentenced each defendant to 52 years for murder and a concurrent 20-year sentence for armed robbery. On appeal, Causey contends that his counsel was ineffective for failing to renew his motions to quash his arrest and suppress his statement after two police detectives testified at trial that Causey did not confess his involvement in Epps\u2019 murder until he had been at the police station for approximately 19 hours. In addition, both defendants assert that the jury was improperly instructed as to the legal definition of felony murder and that their sentences are excessive. For the reasons stated below, we affirm defendants\u2019 convictions. However, because each defendant\u2019s sentences must be served consecutively and not concurrently, we remand this case to the trial court for resentencing.\nEpps was assaulted and murdered in the early morning hours of October 19, 1997, and his body was found in a lot in the 800 block of North Sedgwick Street in Chicago. A nearby 55-gallon garbage can was bloodstained, blood spatters were found on the grass, and pieces of trash were scattered about. An autopsy indicated that Epps died of blunt head trauma due to an assault. Police located no witnesses to the crime. Approximately 18 months later, Causey and Wallace were arrested and charged with Epps\u2019 murder.\nAt a hearing on Causey\u2019s motion to quash his arrest, the trial court heard the following relevant testimony. Causey testified that between 9:30 and 10 p.m. on April 24, 1999, three police officers stopped him as he walked down Larrabee Street. The officers handcuffed Causey and took him to a police station at Chicago and Clark, where he was strip-searched. Causey testified he was 20 years old at the time and that the officers knew him and had stopped him two or three times before.\nIn opposition of Causey\u2019s motion, Chicago police detective Barrett J. Moran testified that in February 1999, he was assigned to investigate Epps\u2019 murder. Moran reviewed police reports indicating that an eyewitness to the murder had identified several suspects, including Causey. At about midnight on April 24, two officers brought Causey to Area 3 police headquarters. When Detective Moran spoke to Causey about an hour later, at 1 a.m. on April 25, Causey sat in an unlocked interview room and was not handcuffed. At that time, Causey confessed his involvement in Epps\u2019 murder. Moran stated that Causey was brought to Area 3 for an interview and that he had been free to leave until he made his inculpatory statement.\nChicago police officer Thomas Parham testified that he and his partner stopped Causey and told him that Area 3 detectives wanted to speak with him. He testified that Causey voluntarily accompanied them to the station. Although the officer patted Causey down before Causey got into the squad car, Causey was not handcuffed or searched. Contrary to Causey\u2019s testimony, the officers did not strip-search him or take him to Chicago and Clark. The trial court denied Causey\u2019s motion to quash his arrest, finding that Causey voluntarily went to Area 3.\nThe trial judge then heard testimony on Causey\u2019s motion to suppress his statement. Detective Moran testified that he first spoke with Causey at about 12:30 or 1 a.m. on April 25. Detective Robert Browne was also present. Causey was not handcuffed. Detective Moran read Causey his Miranda rights. After about 45 minutes, the detectives left the room. The detectives returned 10 minutes later and spoke with Causey for another 15 or 20 minutes. Detective Moran showed Causey several photographs of people that Causey had mentioned. The detectives spoke with Causey again for about 15 minutes, until approximately 3 a.m.\nDetective Moran testified that he, Detective Browne and Cook County Assistant State\u2019s Attorneys Trev Minert and Tony Benish met with Causey between 11 p.m. on April 25 and 2 a.m. on April 26. During that time, Causey did not ask for an attorney or to call his family and was not handcuffed. The detective stated that Causey was never beaten, threatened or told what to say.\nOn cross-examination, Detective Moran said that according to the arrest report, Causey was arrested at 12:30 a.m. on April 26. Regarding his first conversation with Causey at about 1 a.m. on April 25, Detective Moran stated that he read Causey the Miranda warnings prior to the interview. Causey told the detective he was nearby when Epps was killed. Causey then said two people approached him and asked him to be a lookout while they attacked and robbed a man whom they thought had money. Causey said the victim was hit in the head with a garbage can and that he kicked the victim a few times. Causey said he was supposed to \u201cget money for it\u201d but that he did not receive any money.\nDetective Moran stated that as of 1 a.m. on April 25, Causey had not incriminated himself in Epps\u2019 murder. Causey\u2019s counsel impeached the detective with his prior testimony that Causey had confessed his involvement in Epps\u2019 death by that time, to which Detective Moran replied that Causey had started to give a statement at 1 a.m. The detective denied that he or Detective Browne kicked, choked or threatened Causey or prevented Causey from making a phone call. On redirect examination, he said Causey was arrested \u201cwhen we finished our whole investigation.\u201d\nAssistant State\u2019s Attorney Benish testified that at about 4 a.m. on April 26, Causey gave a statement recorded by a court reporter. Benish read portions of the statement in which Causey said he was given food and drink and allowed to smoke and use the bathroom. Benish said Causey was not threatened or coerced into making his statement.\nCausey testified, reiterating his account of being strip-searched at Chicago and Clark. Causey said he was handcuffed while the detectives drove to Area 3, where they led him to a small windowless room and handcuffed him to a wall. Causey said he told the detectives he did not know Epps. Causey said he was not read his Miranda rights or allowed to call his grandmother. Causey said the detectives choked and pushed him and that his inculpatory statement reflected what they told him to say. On cross-examination, Causey admitted he had been arrested 22 times for various offenses. The parties stipulated that Causey had a 1998 felony conviction for possession of a controlled substance.\nThe trial court denied the motion to suppress Causey\u2019s statement, finding that the statement was intelligently, knowingly and voluntarily made. The trial court determined that in light of the testimony that police were investigating other suspects while questioning Causey, it was reasonable that Causey was not charged with a crime immediately after his initial interview. Although the court found that Causey\u2019s initial statement \u201cperhaps was not quite as inculpatory as Detective Moran made it out,\u201d the court found Causey\u2019s testimony to be not credible.\nAt trial, the State established that police sought to question several men regarding Epps\u2019 murder, including Wallace (nicknamed Big Spank), Floyd Rogers (Fuzz), Lorenzo Williams (Zoe) and two other men. Detective Browne testified that at about 1 a.m. on April 25, he and Detective Moran questioned Causey about Epps\u2019 murder. Causey told the detectives that he encountered a group of people, and a man was lying on the ground. Causey said Fuzz struck the man on the head twice with a garbage can, and a man Causey referred to as Spanky kicked Epps. Causey identified a photo of Wallace as Spanky and also identified photos of Rogers and Williams.\nDetective Browne testified that upon resuming work on the afternoon of April 25 for his next shift, he went to Wallace\u2019s home at about 5:30 p.m. and brought Wallace to Area 3 for questioning. After Detective Browne and Detective Moran spoke to Wallace for about 45 minutes, they met alternately with Causey and Wallace from about 7 p.m. to 9 p.m. During that period, Causey told the detectives that Fuzz approached him and Wallace in the lot on Sedgwick Street and asked Causey and Wallace to be lookouts while he robbed a man. When Fuzz struck the man, he and Wallace kicked the man in the stomach. Fuzz hit the man in the head twice with the garbage can. Zoe also struck the victim. Fuzz went through the victim\u2019s pockets.\nOn cross-examination, Detective Browne said that until that conversation, Causey had not admitted to participating in Epps\u2019 murder. When they interviewed Causey from 1 to 3:30 a.m. on April 25, Causey was not under arrest and had not yet incriminated himself. Detective Browne testified that Causey said \u201che would stay there and help us out in this case.\u201d At some point, Causey asked to make a phone call and was allowed to call his grandmother. Detective Browne stated that Causey did not inculpate himself in Epps\u2019 murder until after 7 p.m. on April 25. The detective denied that he or Detective Moran threatened or harmed Causey or forced him to make a statement. On redirect, Detective Browne stated that Causey was the first person interviewed in connection with Epps\u2019 death and that they did not want Causey to leave because they \u201cmay never see him again.\u201d The detective said other officers were looking for Wallace during the day on April 25 while Causey was at the station.\nAssistant State\u2019s Attorney Benish read Causey\u2019s statement to the jury. In the statement, Causey said he was 20 years old and that he waived his Miranda rights. Causey\u2019s statement was consistent with Detective Browne\u2019s testimony.\nFor the defense, Detective Moran testified that Causey first made an inculpatory statement at about 1 a.m. on April 25. However, on cross-examination, the detective stated that in the 1 a.m. statement, Causey only admitted to being at the scene and that he did not admit his involvement in the murder until the 7 p.m. interview that night. On redirect, Detective Moran stated that he believed an inculpatory statement was one in which a suspect \u201cincluded himself in at the scene\u201d and that inculpatory meant \u201cinclusive.\u201d The detective stated that he did not know inculpatory was consistent with admitting guilt.\nCausey testified that he was not involved in Epps\u2019 death and that his statement was coerced. Wallace\u2019s statement was substantially similar to Causey\u2019s. Wallace stated that he saw Rogers take money from Epps\u2019 pocket but did not see how much money Rogers took.\nIn rebuttal, Detective Moran again denied grabbing, pushing or mistreating Causey during the interrogation or promising him he could leave if he gave a statement indicating that he kicked Epps. Following additional rebuttal testimony, the State rested. Their respective juries convicted Causey and Wallace of first degree murder and armed robbery. The trial court sentenced each defendant to 52 years for first degree murder and 20 years for armed robbery, with the sentences to be served concurrently.\nOn appeal, Causey first contends that his trial attorney was ineffective for failing to renew his motion to quash his arrest and suppress evidence in light of Detective Browne\u2019s and Detective Moran\u2019s trial testimony that Causey did not inculpate himself in Epps\u2019 murder until after 7 p.m. on April 25, approximately 19 hours after he was first questioned. To demonstrate ineffective assistance of counsel under Strickland v. Washington, 466 U.S. 668, 80 L. Ed. 2d 674, 104 S. Ct. 2052 (1984), a defendant must show that counsel\u2019s performance was deficient and that the deficient performance prejudiced the defendant such that the result of the proceeding would have been different.\nPursuant to section 114 \u2014 11(g) of the Code of Criminal Procedure of 1963, a motion to suppress a confession on the ground that it was not voluntary \u201cshall be made before trial unless opportunity therefor did not exist or the defendant was not aware of the grounds for the motion.\u201d 725 ILCS 5/114 \u2014 11(g) (West 2000). A pretrial ruling on a motion to suppress is not final and may be changed or reversed at any time prior to a final judgment: People v. Brooks, 187 Ill. 2d 91, 127, 718 N.E.2d 88, 109 (1999). Causey\u2019s attorney filed and argued pretrial motions to quash his arrest and suppress his statement, and the trial court denied both motions.\nWhen a defendant seeks relief in the appellate court to overturn the trial court\u2019s refusal to suppress his statement and the request is based on later-adduced trial evidence, the defendant can rely on trial evidence only if he renewed his suppression motion at trial and asked the court to reconsider its earlier ruling. People v. Centeno, 333 Ill. App. 3d 604, 620, 776 N.E.2d 629, 642 (2002), citing Brooks, 187 Ill. 2d at 127-28, 718 N.E.2d at 109. To successfully assert that counsel was ineffective for failing to file such a motion, the defendant must demonstrate that the motion would have been successful, thus affecting the outcome of the trial. People v. DeLuna, 334 Ill. App. 3d 1, 16, 777 N.E.2d 581, 595 (2002).\nWhile numerous cases have involved the failure of defense counsel to file an initial motion to quash an arrest or suppress evidence, our research has unearthed no precedent specifically involving a Strickland claim for failure to seek the renewal or reopening during trial of a previously unsuccessful motion. Neither Causey nor the State cites to any such specific authority. Based on Centeno and Brooks, we conclude that a defendant could successfully argue that his counsel was ineffective for failing to renew a suppression motion at trial because his attorney\u2019s omission would prevent the defendant from relying on evidence presented at trial to support his argument to this court.\nOur next concern is whether Causey has presented such an argument. For Causey to prevail, he must show that his attorney was deficient in not seeking to renew or reopen the motions during trial. He also must demonstrate that had his counsel done so, the court would have granted the request and, furthermore, that the result of his trial would have been different. Therefore, Causey must show that the trial judge would have reversed his previous decision and granted the motions in light of the trial testimony.\nCausey contends his pretrial motions were \u201cdoomed\u201d until Detective Browne and Detective Moran testified at trial that he did not implicate himself in Epps\u2019 death until 7 p.m. on April 25, approximately 19 hours after he arrived at Area 3 headquarters. Prior to that testimony, Causey argues, his counsel lacked any evidence that Causey\u2019s appearance at the police station \u201cripened into an arrest without probable cause.\u201d We disagree.\nAt the suppression hearing, Detective Moran stated that police records indicated that Causey was arrested at 12:30 a.m. on April 26, approximately 24 hours after he was first questioned. Causey\u2019s attorney impeached the detective with his testimony that Causey had confessed his involvement in Epps\u2019 murder at about 1 a.m. on April 25. The trial court therefore heard testimony at the motion hearing that Causey was at Area 3 headquarters for almost a day before he gave an inculpatory statement. In denying Causey\u2019s pretrial motions, the trial judge expressly considered the inconsistencies in Detective Moran\u2019s testimony and weighed the credibility of the witnesses, including Causey. Based on this record, we cannot conclude that even if Causey\u2019s counsel had moved during trial to renew the motions to quash his client\u2019s arrest and suppress his statements, the trial court would have reversed its previous rulings. If a defendant has not suffered prejudice as a result of his attorney\u2019s actions, we need not consider whether counsel\u2019s performance was deficient. Strickland, 466 U.S. at 697, 80 L. Ed. 2d at 699-700, 104 S. Ct. at 2069-70. Therefore, Causey\u2019s ineffective assistance claim is rejected.\nWe next address the arguments that Causey and Wallace jointly raise. They first assert that the State was required to prove, as an element of felony murder, that Epps\u2019 death was foreseeable. Along with the instructions defining first degree murder and accountability, both juries also received the pattern jury instruction on felony murder:\n\u201cTo sustain the charge of first degree murder, it is not necessary for the State to show that it was or may have been the original intent of the defendant or one for whose conduct he is legally responsible to kill the deceased, Ricardo Epps.\nIt is sufficient if the jury believes from the evidence beyond a reasonable doubt that the defendant and one for whose conduct he is legally responsible combined to do an unlawful act, such as to commit armed robbery, and that the deceased was killed by one of the parties committing that unlawful act.\u201d Illinois Pattern Jury Instructions, Criminal, No. 5.03A (4th ed. 2000) (hereinafter IPI Criminal 4th No. 5.03A).\nTo consider this argument, it is necessary to explain the manner in which defendants were charged and the verdict forms used in this case. Each of the two juries received two verdict forms for first degree murder and two verdict forms for armed robbery pertaining to the defendant whose case it was to decide. The first degree murder forms did not specify a theory of murder, such as intentional murder or felony murder. Depending on the outcome of their deliberations, the jurors were to sign one form if they found a defendant guilty of first degree murder or sign the other form in the case of an acquittal. Each jury returned a form finding its respective defendant guilty of first degree murder. As will be discussed in greater detail later in this opinion, because the jury convicted defendants with a general first degree murder verdict form, the verdict is presumed to apply to any count in the indictment to which the proof is applicable. See People v. Cardona, 158 Ill. 2d 403, 411, 634 N.E.2d 720, 723 (1994). Therefore, defendants were convicted of the offense of first degree murder that carried the most culpable mental state: intentional murder. See Car-dona, 158 Ill. 2d at 411, 634 N.E.2d at 723-24.\nDefendants argue that, given the wording of the felony murder instruction and the use of the general verdict form for first degree murder, it is possible that jurors based their verdicts on a strict liability theory of felony murder, namely that, because a felony occurred, defendants were guilty of the murder committed in the course of that felony.\nTo properly preserve an issue for review, a defendant must object at trial and renew the objection in a written posttrial motion. People v. Enoch, 122 Ill. 2d 176, 186, 522 N.E.2d 1124, 1130 (1988). Although at the jury instruction conference Causey\u2019s attorney protested to the trial judge that IPI Criminal 4th No. 5.03A was \u201can improper instruction,\u201d Causey\u2019s posttrial motion does not refer to the instruction. Wallace\u2019s attempt to preserve the issue is similarly incomplete. His counsel objected to the general verdict form for murder; however, he did not specifically raise the foreseeability issue regarding the jury instruction.\nAlthough a defendant\u2019s failure to object to jury instructions generally forfeits any later claim of error, a failure to properly instruct the jury can constitute plain error. People v. James, 331 Ill. App. 3d 1064, 1068, 773 N.E.2d 1176, 1179 (2002). A trial court is required to \u25a0 give correct instructions on the elements of an offense charged to ensure that the jury can properly assess the case. James, 331 Ill. App. 3d at 1068, 773 N.E.2d at 1179. In reviewing a defendant\u2019s claim regarding instructions, error occurs when \u201cthe jury was not adequately apprised of the State\u2019s burden of proof.\u201d People v. Santos, 333 Ill. App. 3d 1, 6-7, 774 N.E.2d 473, 478 (2002). Because defendants\u2019 arguments involve the validity of the jury instructions, we address them.\nTo convict a defendant of felony murder, the State must prove that, in performing the acts that caused the decedent\u2019s death, the defendant was attempting or committing a forcible felony other than second degree murder. 720 ILCS 5/9 \u2014 1(a)(3) (West 2000). Defendants correctly state that Illinois observes a proximate cause theory of felony murder. See People v. Dekens, 182 Ill. 2d 247, 249, 695 N.E.2d 474, 475 (1998); see also People v. Lowery, 178 Ill. 2d 462, 465-66, 687 N.E.2d 973, 975-76 (1997) (discussing other jurisdictions\u2019 use of an agency theory for felony murder). Under the proximate cause theory, the defendant bears liability for \u201cany death proximately related to the defendant\u2019s criminal conduct.\u201d Dekens, 182 Ill. 2d at 252, 695 N.E.2d at 477.\nDefendants argue that IPI Criminal 4th No. 5.03A is flawed because it defines the offense of felony murder \u201cin terms of strict liability.\u201d However, the wording of the instruction is accurate, precisely because felony murder is premised on strict liability. People v. Hall, 291 Ill. App. 3d 411, 420, 683 N.E.2d 1274, 1280 (1997); People v. McCarroll, 168 Ill. App. 3d 1020, 1023, 523 N.E.2d 150, 152 (1988) (\u201cfelony murder is based on strict liability for one who kills or is responsible for a killing during the commission of a felony\u201d). The State is not required to prove that the defendant could foresee the death or that the defendant intended to commit murder; it merely must show that the defendant intended to commit the underlying felony. People v. McCarty, 329 Ill. App. 3d 969, 982, 769 N.E.2d 985, 995 (2002). As our supreme court noted in People v. Brackett, 117 Ill. 2d 170, 180, 510 N.E.2d 877, 882 (1987), \u201cThere are often cases in which the precise manner of death will not be foreseeable to the defendant while he is committing a felony. This does not relieve the defendant of responsibility.\u201d See also People v. Derr, 316 Ill. App. 3d 272, 277, 736 N.E.2d 693, 699 (2000).\nDefendants\u2019 objections to the general verdict form are admittedly based on their assertion that the jury was not properly instructed as to felony murder. Because we have found the felony murder instruction sufficient, defendants\u2019 arguments as they relate to the verdict form are of no moment. Nevertheless, we find no error in the general verdict form for first degree murder. Illinois recognizes only one offense of murder, and the State is not required to specifically charge a defendant under the subsection denoting felony murder. People v. Toney, 337 Ill. App. 3d 122, 129, 785 N.E.2d 138, 144 (2003). While the jury must be unanimous with respect to a defendant\u2019s guilt or innocence of the crime charged, unanimity is not required regarding the alternate ways in which the crime can be committed. See People v. Rand, 291 Ill. App. 3d 431, 440, 683 N.E.2d 1243, 1249 (1997) (and numerous cases cited therein).\nMoreover, People v. Scott, 243 Ill. App. 3d 167, 612 N.E.2d 7 (1993), on which defendants rely, is easily distinguishable. In Scott, the defendant was charged with three counts of delivery of a controlled substance based on separate transactions to three different undercover officers. Scott, 243 Ill. App. 3d at 169, 612 N.E.2d at 9. However, the jury was given only one verdict form for one count of delivery of a controlled substance. Scott, 243 Ill. App. 3d at 169, 612 N.E.2d at 9. In reversing the defendant\u2019s conviction, this court noted the possibility that the single form contributed to a nonunanimous guilty verdict because the jurors, in finding the defendant guilty of one count of delivery, could have based their verdict on any one of the three transactions. Scott, 243 Ill. App. 3d at 169, 612 N.E.2d at 9. Here, defendants each were charged with one count of murder and each jury received one verdict form for first degree murder, unlike the potentially confusing situation in Scott. We conclude that the jury instructions correctly defined felony murder and also that the use of a general verdict form was proper.\nWe next address the contention of both defendants that their 52-year sentences for first degree murder and 20-year sentences for armed robbery were excessive. In response, the State not only asks this court to affirm defendants\u2019 concurrent sentences, it further argues that the trial court should have imposed consecutive sentences under section 5 \u2014 8\u20144 of the Unified Code of Corrections (730 ILCS 5/5- \u2014 8\u20144 (West 1996)). The State contends that each defendant\u2019s 20-year sentence for armed robbery should be served consecutively to his murder sentence because each defendant was guilty of multiple offenses, including the Class X felony of armed robbery, during which Epps suffered severe bodily injury. The State asks this court to remand the case to the trial court for the imposition of consecutive sentences.\nIn a joint reply brief, defendants contend that the State has forfeited the ability to request consecutive sentences by failing to do so in the trial court. Defendants attempt to circumvent our supreme court\u2019s holding in People v. Arna, 168 Ill. 2d 107, 658 N.E.2d 445 (1995), that a sentence that does not conform to a statutory requirement is void and may be corrected at any time. See also People ex rel. Ryan v. Roe, 201 Ill. 2d 552, 557, 778 N.E.2d 701, 704 (2002). The authority on which defendants rely, People v. Capuzi, 308 Ill. App. 3d 425, 429, 720 N.E.2d 662, 666 (1999), discusses the State\u2019s inability to object to a defendant\u2019s standing for the first time on appeal. Capuzi does not relate to a reviewing court\u2019s ability to correct a sentence and therefore does not contradict Arna.\nDefendants argue that this court must examine \u201cwhether a way exists for the sentencing court to impose a concurrent sentence.\u201d We disagree that we are required to engage in such an analysis, and indeed, defendants later acknowledge that this court\u2019s role is to determine whether the trial court complied with statutory requirements in imposing concurrent sentences. In other words, our task is to assess whether Illinois law mandates consecutive sentences here, because, if that is the case, then defendants\u2019 concurrent sentences are void.\nGenerally, Illinois law prohibits consecutive sentences for multiple offenses by a defendant that were committed in a single course of conduct during which there was no substantial change in the nature of the criminal objective. 730 ILCS 5/5 \u2014 8\u20144(a) (West 1996). The legislature has carved out two exceptions, one of which is relevant to our analysis. Under section 5 \u2014 8\u20144(a), consecutive sentences are required when a defendant is convicted of multiple offenses, including a Class X or Class 1 felony, and the defendant inflicted severe bodily injury. 730 ILCS 5/5 \u2014 8\u20144(a) (West 1996); People v. Curry, 178 Ill. 2d 509, 519, 687 N.E.2d 877, 883 (1997). Furthermore, in 1997, prior to the commission of the crimes with which defendants were charged, section 5 \u2014 8\u20144(b) was amended to mandate consecutive sentences where the defendant was convicted of a Class X or Class 1 felony and the defendant inflicted severe bodily injury even when those offenses were not committed as part of a single course of conduct. Therefore, that amendment to the statute \u201chad the practical effect of requiring consecutive sentences on all triggering offenses, making a determination of whether defendant\u2019s offenses were committed within a single course of conduct no longer relevant\u201d in imposing mandatory consecutive sentences. People v. Carney, 327 Ill. App. 3d 998, 1001, 765 N.E.2d 1028, 1031 (2002). Simply put, consecutive sentences are required where a defendant was convicted of a Class X or Class 1 felony and where severe bodily injury was inflicted during the commission of that felony. People v. Whitney, 188 Ill. 2d 91, 98-99, 720 N.E.2d 225, 229 (1999). Armed robbery is a Class X felony. 720 ILCS 5/18 \u2014 2(b) (West 1996). Defendants were convicted of that triggering offense and also were convicted of first degree murder.\nDefendants contend that this court cannot impose consecutive sentences in the absence of a factual finding by the trial court that Epps sustained severe bodily injury. However, the death of the victim of a triggering offense can be the basis for a finding of severe bodily injury. People v. Thompson, 331 Ill. App. 3d 948, 956, 773 N.E.2d 15, 23 (2002); Carney, 327 Ill. App. 3d at 1001-02, 765 N.E.2d at 1031; People v. Sergeant, 326 Ill. App. 3d 974, 990, 762 N.E.2d 518, 532 (2001). In Thompson, the defendant and his accomplice entered a cab and, upon arriving at their destination, the defendant shot the cab driver in the back of the head and took $23 from the driver\u2019s pocket. Thompson, 331 Ill. App. 3d at 950, 773 N.E.2d at 18. The trial court sentenced the defendant to consecutive terms for murder and armed robbery. Thompson, 331 Ill. App. 3d at 950-51, 773 N.E.2d at 18. The appellate court affirmed, finding that section 5 \u2014 8\u20144(a) required consecutive terms because \u201cthe victim\u2019s death, i.e., the severe bodily injury, occurred essentially simultaneously with the armed robbery and, hence, the victim\u2019s death occurred during the commission of the triggering crime as directed by Whitney.\u201d Thompson, 331 Ill. App. 3d at 956-57, 773 N.E.2d at 23.\nThe facts of this case warrant the same result as in Thompson. Acting as a lookout constitutes aiding and facilitating the commission of the offense, and if that is proven, defendants are legally responsible for the crime under an accountability theory. People v. McComb, 312 Ill. App. 3d 589, 594, 728 N.E.2d 503, 507 (2000). Causey admitted to acting as a lookout while Rogers and Williams robbed Epps. Causey told police that while Rogers hit Epps on the head with a metal garbage drum, he and Wallace kicked Epps in the stomach. Rogers then went through Epps\u2019 pockets and, according to Wallace, retrieved money. The evidence is sufficient to support a finding that Epps\u2019 death occurred during the commission of the triggering offense of armed robbery, and therefore, consecutive sentences are mandated. See People v. Sangster, 91 Ill. 2d 260, 265-66, 437 N.E.2d 625, 628 (1982) (mandatory consecutive sentencing applies even when defendant is convicted on accountability theory); People v. Guzman, 276 Ill. App. 3d 750, 762, 658 N.E.2d 1268, 1277 (1995); People v. Ratzke, 253 Ill. App. 3d 1054, 1062, 625 N.E.2d 1004, 1010 (1993).\nIn response to defendants\u2019 remaining assertions, it is true that consecutive sentences imposed under section 5 \u2014 8\u20144 can constitute an impermissible double enhancement when the sentences are based on the infliction of severe bodily injury and when severe bodily injury is inherent in the triggering offense. See People v. Phelps, 329 Ill. App. 3d 1, 7-11, 768 N.E.2d 168, 173-77 (2002), appeal allowed, 201 Ill. 2d 602, 786 N.E.2d 195 (2002). However, although first degree murder currently can serve as a triggering offense under the current version of the statute, that was not the case when defendants were charged. The triggering offense in this case was armed robbery, which does not contain severe bodily injury as an element. See 720 ILCS 5/18 \u2014 2, 18 \u2014 1 (West 1998). See also People v. Ollie, 333 Ill. App. 3d 971, 992-93, 777 N.E.2d 529, 546 (2002) (consecutive sentences proper when defendant was convicted of home invasion, a Class X felony, and the victim\u2019s death occurred during the commission of that offense). As in Ollie, the double enhancement considerations in Phelps are not at issue here.\nWe likewise reject defendants\u2019 assertions that armed robbery is a lesser included offense of intentional murder and that the armed robbery conviction should be vacated, thus precluding the imposition of consecutive sentences. Defendants argue that without their involvement in the armed robbery, they could not have been convicted of Epps\u2019 murder on an accountability theory.\nAn offense is a lesser included offense of another if the charged greater offense requires the jury to find a disputed factual element that is not required for conviction of the lesser offense. People v. Novak, 163 Ill. 2d 93, 108, 643 N.E.2d 762, 770 (1994). In People v. Sample, 326 Ill. App. 3d 914, 928-29, 761 N.E.2d 1199, 1210-11 (2001), this court rejected the argument that armed robbery is a lesser included offense of intentional murder. We agree with Sample because the opposite of the Novak standard is true: Armed robbery includes an element not included in intentional murder, namely, the taking of property. Thus, armed robbery cannot be an included offense of intentional murder. In conclusion, for all of those reasons, defendants\u2019 concurrent sentences are void because consecutive sentences are mandatory in this case under section 5 \u2014 8\u20144.\nDefendants\u2019 final contention on appeal is that the length of their individual sentences is excessive in light of their age and rehabilitative potential. Because we have concluded that defendants\u2019 52-year sentences for murder and 20-year sentences for armed robbery must be served consecutively, their 52-year prison terms would become, in effect, 72-year terms.'\nThe State suggests that this case be remanded to the trial court for the imposition of consecutive sentences. The appellate court can correct a void sentence at any time and is not barred from ordering consecutive terms even though that would effectively increase the defendants\u2019 sentences. See Arna, 168 Ill. 2d at 113, 658 N.E.2d at 448. However, it is obvious that when the trial judge sentenced defendants, he did so under the impression that the sentences would be served concurrently. Given the circumstances of this case, including the requirement that defendants\u2019 terms be served consecutively, the trial judge is in the best position to consider the aggregate sentence to be served. Defendants\u2019 convictions are affirmed, and this case is remanded to the trial court for resentencing to consecutive terms in accordance with this opinion. For that reason, we need not address defendants\u2019 assertions regarding their individual sentences.\nAffirmed and remanded.\nO\u2019BRIEN, EJ., and O\u2019MARA FROSSARD, J., concur.\nThroughout the record and briefs, Causey\u2019s first name is spelled both Lettories and Letorries. We adopt the latter spelling, which Causey offered in his testimony.\nGiven that pretrial testimony, we also reject Causey\u2019s argument that the State failed to disclose exculpatory evidence as required by Brady v. Maryland, 373 U.S. 83, 10 L. Ed. 2d 215, 83 S. Ct. 1194 (1963).\nEffective January 1, 2000, Public Act 91 \u2014 144 added first degree murder as a triggering offense in sections 5 \u2014 8\u20144(a) and 5 \u2014 8\u20144(b).", "type": "majority", "author": "JUSTICE GALLAGHER" } ], "attorneys": [ "Rita A. Fry, Public Defender, of Chicago (James N. Perlman, Assistant Public Defender, of counsel), for appellants.", "Richard A. Devine, State\u2019s Attorney, of Chicago (Renee Goldfarb, Alan J. Spellberg, and Jane Liechty Loeb, Assistant State\u2019s Attorneys, of counsel), for the People." ], "corrections": "", "head_matter": "THE PEOPLE OF THE STATE OF ILLINOIS, Plaintiff-Appellee, v. LETORRIES CAUSEY, Defendant-Appellant. \u2014 THE PEOPLE OF THE STATE OF ILLINOIS, Plaintiff-Appellee, v. NORMAN WALLACE, Defendant-Appellant.\nFirst District (6th Division)\nNos. 1 \u2014 01\u20141984, 1 \u2014 01\u20142590 cons.\nOpinion filed June 27, 2003.\nRita A. Fry, Public Defender, of Chicago (James N. Perlman, Assistant Public Defender, of counsel), for appellants.\nRichard A. Devine, State\u2019s Attorney, of Chicago (Renee Goldfarb, Alan J. Spellberg, and Jane Liechty Loeb, Assistant State\u2019s Attorneys, of counsel), for the People." }, "file_name": "0759-01", "first_page_order": 777, "last_page_order": 792 }