People v. Yohn

── People v. Yohn ── Court: Appellate Court of Illinois Date: May 26, 2026 Category: General NOTICE 2026 IL App (4th) 250326-U This Order was filed under FILED Supreme Court Rule 23 and is May 26, 2026 NO. 4-25-0326 Carla Bender not precedent except in the th limited circumstances allowed 4 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. ) Adams County BRADLEY SCOTT YOHN, ) No. 21CF715 Defendant-Appellant. ) ) Honorable ) Roger B. Thomson, ) Judge Presiding. JUSTICE HARRIS delivered the judgment of the court. Justices Zenoff and Vancil concurred in the judgment. ORDER ¶1 Held: (1) The trial court did not abuse its discretion in finding the deceased victim’s out- of-court statements were admissible at defendant’s jury trial under the excited utterance exception to the hearsay rule. (2) The trial court did not err in finding the statements were nontestimonial and therefore did not implicate defendant’s right to confrontation. ¶2 A jury found defendant, Bradley Scott Yohn, guilty of home invasion (720 ILCS 5/19-6(a)(1) (West 2020)), aggravated kidnapping (id. § 10-2(a)(5)), aggravated vehicular hijacking (id. § 18-4(a)(1)), and aggravated criminal sexual assault (id. § 11-1.30(a)(1)), and he was sentenced to 130 years in prison. Defendant appeals his convictions, arguing on appeal that the trial court “erred in allowing the State to admit out-of-court, testimonial statements the deceased complainant made to her husband and a sheriff’s deputy for the truth of the matter asserted where no hearsay exception existed, in violation of the hearsay rule and [the] right to confrontation.” We affirm. ¶3 I. BACKGROUND ¶4 A. The Charges ¶5 In November 2021, defendant was indicted on two counts of home invasion (counts I and II) (id. § 19-6(a)(1), (6)) and one count each of aggravated kidnapping (count III) (id. § 10-2(a)(5)), aggravated vehicular hijacking (count IV) (id. § 18-4(a)(1)), aggravated criminal sexual assault (count V) (id. § 11-1.30(a)(1)), and residential burglary (count VI) (id. § 19-3(a)). The indictments were based on allegations that defendant approached the alleged victim, C.L.—who was 60 years of age or older—in her parked car under the pretext of offering assistance, then commandeered the vehicle and drove it to C.L.’s residence, where he proceeded to sexually assault her, burglarize the home, and flee the area in her vehicle. C.L. died before defendant’s trial, but the State indicated at a pretrial hearing that it was “not going to present any evidence or somehow allege that [defendant] caused that death.” ¶6 B. Pretrial Proceedings ¶7 Prior to trial, the trial court granted defendant’s request to proceed pro se and allowed his previously appointed counsel to serve as standby counsel at his trial. Defendant