People v. Ortega

── People v. Ortega ── Court: Appellate Court of Illinois Date: April 24, 2026 Category: General NOTICE 2026 IL App (4th) 250337-U This Order was filed under FILED Supreme Court Rule 23 and is April 24, 2026 not precedent except in the NO. 4-25-0337 Carla Bender limited circumstances allowed 4th District Appellate under Rule 23(e)(1). IN THE APPELLATE COURT Court, IL OF ILLINOIS FOURTH DISTRICT THE PEOPLE OF THE STATE OF ILLINOIS, ) Appeal from the Plaintiff-Appellee, ) Circuit Court of v. ) Winnebago County CHARLOTTE ORTEGA, ) No. 23CM2462 Defendant-Appellant. ) ) Honorable ) Tamika R. Walker, ) Judge Presiding. JUSTICE CAVANAGH delivered the judgment of the court. Justices Lannerd and Vancil concurred in the judgment. ORDER ¶1 Held: The appellate court affirmed, finding (1) the evidence was sufficient for a jury to reasonably conclude defendant was guilty beyond a reasonable doubt of battery, (2) defendant forfeited her claim the trial court erred when excluding evidence of the victim’s aggressive and violent character, and (3) the court’s restitution order was appropriate. ¶2 Defendant, Charlotte Ortega, was convicted by a jury of battery (720 ILCS 5/12-3(a)(2) (West 2022)). She was subsequently sentenced to 18 months’ conditional discharge and ordered to pay $1,808 in restitution for an ambulance bill. On appeal, she argues (1) the State failed to prove her guilty beyond a reasonable doubt, (2) the trial court abused its discretion when it excluded evidence of the victim’s aggressive and violent character, and (3) the court erred when ordering her to bear the entire burden of restitution. We disagree and affirm. ¶3 I. BACKGROUND ¶4 In December 2023, defendant was charged by complaint with battery (id.) for knowingly making physical contact of an insulting or provoking nature with Laura Morales when she repeatedly struck Morales on her head and body. ¶5 In June 2024, prior to trial, defendant filed a motion asserting the affirmative defense of self-defense pursuant to section 7-1 of the Criminal Code of 2012 (720 ILCS 5/7-1 (West 2022)). Defendant also filed a supplemental motion for discovery requesting the State produce and disclose evidence of Morales’s prior acts of violence pursuant to (1) defendant’s claim of self-defense, (2) People v. Lynch, 104 Ill. 2d 194 (1984), and (3) People v. Gossett, 115 Ill. App. 3d 655 (1983). ¶6 The matter proceeded to a jury trial in November 2024. The following exchange occurred between the trial court and the parties: “THE COURT: All right. Are there any prior conduct motions by the defense? Like Gossett-Lynch issues or anything like that. MS. GALLAGHER [(DEFENDANT’S ATTORNEY)]: Judge, I have filed Gossett-Lynch. I have received all Gossett-Lynch material. THE COURT: All right. [Are] there any motions that we need to take up regarding that issue? MS. GALLAGHER: Judg