People v. Knuckles

165 Ill. 2d 125, 209 Ill. Dec. 1, 650 N.E.2d 974 (1995)

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People v. Knuckles

Illinois Supreme Court
165 Ill. 2d 125, 209 Ill. Dec. 1, 650 N.E.2d 974 (1995)

Facts

In 1984, the People of Illinois (the state) (plaintiff) charged Pamela J. Knuckles (defendant) and her siblings with murder for the strangulation death of their mother. Two weeks after her arrest, Knuckles was interviewed by a psychiatrist, Dr. Kyle Rossiter, who was hired by Knuckles’s counsel to determine Knuckles’s fitness for trial. Dr. Rossiter took notes from the interview but did not prepare a report or testify at any of Knuckles’s proceedings. In fact, Knuckles entered a guilty plea and received a 33-year sentence. However, Knuckles’s conviction was overturned due to ineffective assistance of counsel. Six years later upon retrial, Knuckles raised an insanity defense and provided the state a list of expert witnesses whom she intended to call at trial. Knuckles did not include Dr. Rossiter in her list of experts. The state proceeded to invoke its right to have Knuckles examined by a psychiatrist and subpoenaed Dr. Rossiter’s notes and testimony at trial. The trial court granted Knuckles’s motion to quash the state’s subpoena, the motion was sustained, and the state appealed. An appellate court affirmed the trial court’s order, and the state petitioned for leave to appeal, arguing a need for the testimony and notes because they provided the best impression of Knuckles’s mental state at the time of the murder.

Rule of Law

Issue

Holding and Reasoning (McMorrow, J.)

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