People v. Griggs

── People v. Griggs ── Court: Appellate Court of Illinois Date: April 15, 2026 Category: General NOTICE 2026 IL App (5th) 230586-U NOTICE Decision filed 04/15/26. The This order was filed under text of this decision may be NO. 5-23-0586 Supreme Court Rule 23 and is changed or corrected prior to the filing of a Petition for not precedent except in the IN THE limited circumstances allowed Rehearing or the disposition of the same. under Rule 23(e)(1). APPELLATE COURT OF ILLINOIS FIFTH DISTRICT ______________________________________________________________________________ THE PEOPLE OF THE STATE OF ILLINOIS, ) Appeal from the ) Circuit Court of Plaintiff-Appellee, ) Vermilion County. ) v. ) No. 21-CF-30 ) JAEVIN GRIGGS, ) Honorable ) Derek J. Girton, Defendant-Appellant. ) Judge, presiding. ______________________________________________________________________________ PRESIDING JUSTICE CATES delivered the judgment of the court. Justices McHaney and Sholar concurred in the judgment. ORDER ¶1 Held: The defendant’s convictions are affirmed where the evidence was sufficient to find the defendant guilty beyond a reasonable doubt and the proximate cause theory of felony murder did not violate the defendant’s rights. The defendant’s right to due process was not violated and the defendant’s claim regarding judicial estoppel is without merit. The trial court did not abuse its discretion by failing to allow a prior consistent statement. Finally, trial counsel was not ineffective. ¶2 Following a jury trial, the defendant, Jaevin Griggs, was found guilty of one count of first degree felony murder causing the death of Wyatt Bailey (720 ILCS 5/9-1(a)(1) (West 2018)), one count of first degree murder causing the death of Clayvonte Sloan (720 ILCS 5/9-1(a)(3) (West 2018)), and one count of armed robbery (720 ILCS 5/18-2(a)(2) (West 2018)). The jury also found that the defendant discharged the firearm that caused the deaths of these individuals. The defendant was sentenced to the Illinois Department of Corrections for two consecutive 20-year terms for each of the first degree murder convictions. On appeal, the defendant alleges the following: (1) the State 1 failed to prove the defendant guilty beyond a reasonable doubt, (2) trial counsel was ineffective, (3) the trial court abused its discretion by prohibiting prior consistent testimony given by a witness at a co-offender’s trial, (4) the State violated due process or was judicially estopped from impeaching a witness with a prior inconsistent statement, and (5) the application of the proximate cause theory of felony murder violated the defendant’s due process and his rights under the eighth amendment. For the following reasons, we affirm. ¶3 I. BACKGROUND ¶4 On January 16, 2021, Dustin Cooper contacted Wyatt Bailey to buy cannabis products from Wyatt Bailey via Snapchat messages. The following day, Cooper, the def