People v. Jackson
CourtAppellate Court of Illinois
Date FiledOctober 28, 2026
Docket1-25-1129
StatusUnpublished
📰 News Coverage: Read the LAWS.com news report on this case
Full Opinion
2026 IL App (1st) 251129-U
No. 1-25-1129
Order filed October 28, 2026
NOTICE: This order was filed under Illinois Supreme Court Rule 23 and is not
precedential except in the limited circumstances allowed under Rule 23(e)(1).
IN THE
APPELLATE COURT OF ILLINOIS
FIRST DISTRICT, THIRD DIVISION
THE PEOPLE OF THE STATE OF ILLINOIS, Plaintiff-Appellee,
v.
BRIANA JACKSON, Defendant-Appellant.
Appeal from the Circuit Court of Cook County.
Honorable Ursula Walowski, Judge, Presiding.
Nos. 24 CR 60076
PRESIDING JUSTICE QUISH delivered the judgment of the court.
Justices Lampkin and Rochford concurred in the judgment.
ORDER
¶1 Held: Convictions for aggravated battery and criminal damage to property affirmed where
the evidence was sufficient for the trial court to find that the victim suffered great
bodily harm beyond a reasonable doubt.
¶2 Following a bench trial, defendant Briana Jackson was convicted of aggravated battery
(720 ILCS 5/12-3.05(a)(1) (West 2022)) and criminal damage to government-supported property
(720 ILCS 5/21-1.01(a)(1) (West 2022)) and was sentenced to concurrent terms of two years’
probation with the Adult Probation Mental Health Unit. On appeal, defendant contends that the
State failed to prove her guilty of aggravated battery beyond a reasonable doubt where the victim’s
testimony regarding her medical diagnoses for her injuries was not corroborated by medical
records or expert testimony. For the following reasons, we affirm.
¶3 I. BACKGROUND
¶4 Arelia Boston-Turnipseed testified at trial that, on September 27, 2023, she was working
at the United States Post Office at 4601 South Cottage Grove Avenue in Chicago. At about 10 a.m.,
Boston-Turnipseed was assisting a couple at her service window and directed them to an area at
the back of the office to take their passport photos.
¶5 Before Boston-Turnipseed could close her service window to join the couple, defendant
approached the window and said she wanted to cash a money order. Boston-Turnipseed stated that
she was unable to do so at that time because she did not have enough money in her drawer. Boston-
Turnipseed advised that when a coworker returned from a break, Boston-Turnipseed would check
if the coworker had enough money in her drawer.
¶6 Defendant became angry and loudly stated that Boston-Turnipseed told defendant the same
thing the day before. Boston-Turnipseed asked defendant if she wanted to speak with a supervisor.
Defendant then began “going off.” Boston-Turnipseed paged a supervisor. Boston-Turnipseed’s
coworker, Breanna Kelly, then returned from her break and said she did not have enough money
in her drawer to cash the money order. Boston-Turnipseed offered to call another post office to see
if it could cash it. Defendant was irate and said she did not have enough “f***ing money” to go to
another post office. Defendant moved to Kelly’s window and a letter carrier came to the window
to speak with defendant. Boston-Turnipseed called the police.
¶7 Boston-Turnipseed left her window, walked to the back of the office, and took the couple’s
passport photos. She then heard a loud noise and returned to the lobby. Boston-Turnipseed
observed defendant grabbing the payment card machines off the service counter. Defendant stated,
-2-
“I’ll come back there and get you,” and attempted to jump through Boston-Turnipseed’s service
window.
¶8 Boston-Turnipseed walked into the lobby. Defendant removed herself from the service
window, approached Boston-Turnipseed, and said, “[n]ow what the eff you going to do?” Boston-
Turnipseed replied, “[a]nd what you gonna do?” Defendant pushed Boston-Turnipseed in the chest
with her hand. Boston-Turnipseed walked to the vestibule to see if the police had arrived. She
began to lock the door to prevent customers from entering and defendant from leaving.
¶9 Defendant approached Boston-Turnipseed, struck her face with a fist, then began swinging
both fists, hitting Boston-Turnipseed “probably” more than once. Boston-Turnipseed then began
defending herself and grabbed defendant’s hair, wrapped it around her hand, and pulled defendant
down. Simultaneously, defendant rushed at Boston-Turnipseed, who fell backwards and hit her
head on a steel and glass door. Boston-Turnipseed fell hard onto the floor. She felt pain
immediately.
¶ 10 A man and woman entered the vestibule and pulled defendant off Boston-Turnipseed. The
man took defendant outside. Boston-Turnipseed needed help from others to stand. She
immediately felt pain in her right knee. She also had pain in her neck, left shoulder, and right
thumb. The police arrived and spoke with Boston-Turnipseed. About 15 minutes later, a police car
arrived with defendant in the back seat and Boston-Turnipseed identified her.
¶ 11 An ambulance transported Boston-Turnipseed to a hospital where she underwent x-rays
and was treated for a concussion. She was released from the hospital the same day. Days later,
Boston-Turnipseed saw her primary care doctor who ordered MRIs. Boston-Turnipseed testified
that the MRIs showed that, due to defendant’s actions, she sustained three bulging discs in her
neck, a contusion to her thumb, a rotator tear on her left arm, and a torn meniscus in her right knee.
-3-
¶ 12 Boston-Turnipseed testified that, prior to defendant’s attack, she saw her doctor on a
regular basis and had never been treated for a concussion, nor did she have a tear on her shoulder
or a torn meniscus in her right knee. She had surgery on her left shoulder more than 20 years earlier
but had no shoulder issues since then. Since the date of the incident, she had been on medical leave
without pay.
¶ 13 Photographs of Boston-Turnipseed in the hospital, sitting in a wheelchair and wearing a
neck brace, were admitted into evidence. Three videos recorded by cameras inside the post office
were also admitted. The videos, which are included in the record on appeal, depict defendant
damaging computer equipment and briefly confronting Boston-Turnipseed in the lobby, but do not
show the physical altercation in the vestibule.
¶ 14 On cross-examination, Boston-Turnipseed testified that she had not locked the front door
to the post office when defendant entered the vestibule. Defendant could have exited the building
through a side door. Boston-Turnipseed acknowledged that she walked down some stairs while
talking to the police, signed the complaints with her right hand, and could recall what happened.
She could not recall if she had a knee x-ray but remembered having an ice pack for her knee. When
she awoke the next day, her entire body was sore and in pain. She took three baths a day with
Epsom salt. Boston-Turnipseed never gave her MRI records to the police or prosecutor because
they never asked for them.
¶ 15 Boston-Turnipseed acknowledged that, prior to the incident in this case, she previously saw
a doctor for a ligament sprain and acute pain in her left knee and had a full knee replacement.
Around 2008, she had surgery on her left shoulder and thereafter had post-traumatic osteoarthritis
of that shoulder. She also had been treated for wrist pain from carpal tunnel syndrome, a herniated
intervertebral disc of her lumbar spine, and a left sciatic nerve disorder in her back.
-4-
¶ 16 On redirect examination, Boston-Turnipseed confirmed that the prior herniated disc in her
spine was “totally different” than the herniated disc in her neck following defendant’s attack. Over
defense counsel’s objection, Boston-Turnipseed confirmed that the tear in her rotator cuff, the torn
meniscus in her knee, and the pain in her thumb were “new” injuries that did not exist prior to
defendant’s attack. Boston-Turnipseed testified that when she attempted to lock the door and
defendant entered the vestibule, defendant did not head for the door but, instead, attacked Boston-
Turnipseed.
¶ 17 Letter carrier Tiara Hudson testified that about 10:30 a.m. on September 27, 2023, she
observed defendant yelling at Boston-Turnipseed at the service window in the post office lobby.
Boston-Turnipseed was calm. Hudson asked defendant what was wrong. Defendant stated that she
wanted to speak with a manager because Boston-Turnipseed refused to cash defendant’s money
order. Hudson told defendant that no manager was on duty and suggested she go to another post
office. Defendant replied that she did not have bus fare to go to another post office. Hudson gave
defendant the same explanation Boston-Turnipseed had given. Another clerk came to the service
window and gave defendant the same explanation. Defendant was still irate and loud.
¶ 18 When the clerk tried to close her window, defendant reached in and swung at her. Hudson
then heard a loud crash and saw that defendant had knocked the payment machine off the service
counter. Defendant reached through the service window and knocked over a register, a computer,
and a keypad. Defendant grabbed a pack of batteries and threw them inside the window attempting
to hit someone.
¶ 19 Hudson observed Boston-Turnipseed enter the lobby and saw defendant approach her.
Defendant hit or pushed Boston-Turnipseed, who stumbled backwards. Boston-Turnipseed did not
attempt to strike defendant but, instead, entered the vestibule and attempted to lock the main door.
-5-
Hudson saw defendant run into the vestibule and “attack” Boston-Turnipseed. Defendant punched
Boston-Turnipseed in the face with a closed fist about 10 times. Boston-Turnipseed tried to defend
herself by grabbing at defendant’s hands and pushing her away. From the force of defendant’s
body, Boston-Turnipseed’s head was pushed against a glass window. Hudson and several
coworkers ran into the lobby as defendant continued attacking Boston-Turnipseed. Defendant
attempted to run and was restrained by a customer.
¶ 20 Postal Inspector Sasha Douyon testified regarding the property damage and identified
photographs depicting damage to several pieces of equipment at the clerk’s station. All the
equipment had to be replaced, and the estimated amount of the damage was $1,900.
¶ 21 Chicago Police Officer Andrew Hamilton testified that about 10:30 a.m. on September 27,
2023, he responded to the post office for an assault in progress and saw a man on the sidewalk
holding onto defendant, who was seated on the ground. When Hamilton approached defendant to
handcuff her, defendant fled. Shortly thereafter, Hamilton and other officers detained defendant in
a nearby backyard. Defendant was placed in a police car and driven to the post office where
Boston-Turnipseed identified her in a show-up.
¶ 22 On cross-examination, Hamilton testified that when he arrived at the post office, Boston-
Turnipseed was able to walk outside, recount what had occurred, walk down stairs to the police
car, and sign the complaints. Hamilton did not notice any visible injuries to her at that time.
¶ 23 The defense presented a stipulation that Dr. Narayan Sundaram would testify that on
September 27, 2023, no x-rays were taken of Boston-Turnipseed’s knees and there was no
documentation regarding any injuries to her knees. X-rays were taken of her shoulder, hand, head,
and cervical spine. The x-rays showed no acute fracture or malalignment of her shoulder or hand,
and the impression for both was that she had osteoarthritis.
-6-
¶ 24 Dr. Sundaram would further testify that CT scans of Boston-Turnipseed’s head and cervical
spine showed no evidence of acute intracranial hemorrhage, fracture, or subluxation. The vertebral
body and disc space heights were preserved with no significant bony spinal canal stenosis and no
evidence of acute intracranial hemorrhage or calvarial fracture.
¶ 25 Defendant testified that, on September 27, 2023, she went to the post office to cash a money
order and Boston-Turnipseed stated that she did not have enough money in her drawer. Defendant
told Boston-Turnipseed that she told defendant the same thing the previous day and said that
Boston-Turnipseed could cash the money order the next morning. Defendant asked to speak with
a supervisor and was told no one was available. Defendant became frustrated and upset.
¶ 26 Defendant testified that Boston-Turnipseed went to the back of the office to assist other
customers and another postal worker came to the counter. Defendant told the worker that defendant
did not understand why she could not cash her money order and asked to speak with a supervisor.
The worker told defendant the same thing Boston-Turnipseed had said. Defendant again asked to
speak with a supervisor. The worker handed defendant her money order and said, “[y]eah, you’re
a dumb b***h.”
¶ 27 Defendant testified that she felt verbally attacked and offended, and the situation escalated
quickly. Defendant was already irritated and in a bad state of mind when she entered the post office
because she had not taken her medication for a few months, recently lost her children, and was
being evicted. Defendant suffered from schizoaffective disorder, bipolar disorder, post-traumatic
stress disorder, and depression. Defendant acknowledged that she responded irrationally when she
damaged the equipment in the post office.
¶ 28 When she tried to leave the post office, Boston-Turnipseed came from the back of the office
and walked towards her. Boston-Turnipseed leaned back like she would hit defendant and
-7-
defendant took a defensive stance. Defendant denied making any contact with Boston-Turnipseed.
Defendant went to a door to exit the building, but it was already locked. Defendant then noticed
that Boston-Turnipseed was locking the main door and ran towards it to exit the building.
¶ 29 Boston-Turnipseed grabbed defendant by her hair and pulled her backwards, causing both
women to fall. Defendant testified that she was 5 feet 11 inches tall and that Boston-Turnipseed
was “probably all of five feet.” Defendant explained that the height and weight of her body pushed
Boston-Turnipseed backwards and off balance which caused Boston-Turnipseed to fall backwards
and hit her head.
¶ 30 Several customers ran into the vestibule and tried to restrain defendant by grabbing her
from behind. Defendant moved her arms in a forward circular motion as she tried to break free
from the customers to exit the building. She testified that she is strong when she is “in a manic
episode mode.” Defendant denied punching Boston-Turnipseed at any point.
¶ 31 When the police arrived, defendant ran because she was scared and panicked. At the police
station, defendant was in a “little mode” and tried to kill herself. The police took her to a hospital
where she stayed for five days.
¶ 32 On cross-examination, defendant admitted that she damaged the computer equipment, but
denied that she attacked or punched Boston-Turnipseed. Defendant maintained that she was
attempting to leave the post office when people restrained her. She denied that she had anything to
do with Boston-Turnipseed being injured.
¶ 33 The trial court found the testimony of Boston-Turnipseed, Hudson, Douyon, and Officer
Hamilton clear, “very credible,” and corroborated and found defendant’s testimony not credible.
The court found that defendant intentionally attacked Boston-Turnipseed and no evidence showed
that defendant acted in self-defense or that her actions were excused due to mental illness. The
-8-
court noted that great bodily harm must consist of more than a bruise or pain and found that Boston-
Turnipseed’s explanation of how she was injured and the injuries she sustained established that
she suffered injuries “beyond pain.” The court stated that the evidence that Boston-Turnipseed was
attacked, fell, and hit her head against glass supported its finding that she sustained great bodily
harm.
¶ 34 The court acknowledged that Boston-Turnipseed was previously treated for some medical
conditions and that the medical staff in the emergency room took x-rays and released her. The court
found, however, that did not discredit Boston-Turnipseed’s testimony about defendant’s attack and
the injuries she sustained as a result. Accordingly, the trial court found defendant guilty of
aggravated battery and criminal damage to government-supported property.
¶ 35 In her motion for a new trial, defendant argued that the trial court erred when it allowed
Boston-Turnipseed to testify that she suffered a concussion and had three bulging discs in her neck,
a contusion to her thumb, a rotator tear in her left shoulder, and a meniscus tear to her right knee.
Defendant argued that the injuries were medical diagnoses or conclusions that required expert
testimony to be admissible under Illinois Rule of Evidence 701(c) (eff. Jan. 1, 2011). Defendant
further asserted that when the court found that Boston-Turnipseed suffered great bodily harm, it
erroneously relied on the actions that occurred during the incident, specifically, that Boston-
Turnipseed was attacked, fell, and hit her head on glass, rather than focusing on the injuries she
sustained. Defendant argued that, because the court relied on improper evidence, the State failed
to prove beyond a reasonable doubt that Boston-Turnipseed suffered great bodily harm.
¶ 36 In ruling on defendant’s motion, the trial court stated that it considered all the evidence
when it concluded that Boston-Turnipseed suffered great bodily harm. The court stated that
Boston-Turnipseed’s testimony about what happened to her was not improper and that expert
-9-
testimony was not required to support her testimony regarding the MRIs she underwent and the
conditions for which she was told she was being treated. The court further stated that it is sufficient
for a victim to testify about her injuries, how she felt, why she went to the doctor, and what the
doctor did. The court, therefore, denied defendant’s motion for a new trial and sentenced defendant
to concurrent terms of two years’ probation with the Adult Probation Mental Health Unit.
¶ 37 II. ANALYSIS
¶ 38 On appeal, defendant contends that the State failed to prove her guilty of aggravated battery
beyond a reasonable doubt because it did not establish that Boston-Turnipseed suffered great
bodily harm. Defendant argues that the only evidence of great bodily harm was Boston-
Turnipseed’s testimony regarding diagnoses made by her primary care doctor and photographs that
“inexplicably” show her wearing a neck brace. Defendant further argues that the x-rays showed
no internal injuries and that Officer Hamilton did not observe any visual injuries. Defendant points
out that Boston-Turnipseed acknowledged previous treatment for other medical conditions.
Defendant asserts, without further argument, that Boston-Turnipseed’s testimony regarding her
medical diagnoses was inadmissible because it was not corroborated by medical records or expert
testimony as required by Illinois Rule of Evidence 701(c) (eff. Jan. 1, 2011). Defendant therefore
maintains that, without that testimony, the State failed to prove great bodily harm. She also claims
that the trial court impermissibly rested its finding of great bodily harm on defendant’s actions
rather than the injuries sustained by Boston-Turnipseed.
¶ 39 When a defendant claims the evidence is insufficient to sustain a conviction, this court
must determine whether, after viewing the evidence in the light most favorable to the State, any
rational trier of fact could have found the elements of the offense proved beyond a reasonable
doubt. People v. McLaurin, 2020 IL 124563, ¶ 22 (citing Jackson v. Virginia, 443 U.S. 307, 319
- 10 -
(1979)). This standard applies whether the evidence is direct or circumstantial and does not allow
this court to substitute its judgment for that of the fact finder on issues involving witness credibility
and the weight of the evidence. People v. Jackson, 232 Ill. 2d 246, 280-81 (2009). This court will
not retry the defendant. People v. Jones, 2023 IL 127810, ¶ 28. On review, we must draw all
reasonable inferences from the evidence in favor of the State. Id.
¶ 40 In a bench trial, the trial court determines the credibility of the witnesses, weighs the
evidence, resolves conflicts in the evidence, and draws reasonable inferences therefrom. People v.
Siguenza-Brito, 235 Ill. 2d 213, 228 (2009). In weighing the evidence, the fact finder is not
required to disregard the inferences that naturally flow from that evidence, nor must it search for
any possible explanation consistent with innocence and raise it to the level of reasonable doubt.
Jackson, 232 Ill. 2d at 281. We will not reverse a criminal conviction based upon insufficient
evidence unless the evidence is so improbable or unsatisfactory that reasonable doubt exists as to
the defendant’s guilt. Jones, 2023 IL 127810, ¶ 28.
¶ 41 To prove defendant guilty of aggravated battery as charged, the State had to establish that,
in committing a battery, defendant knowingly caused great bodily harm to Boston-Turnipseed by
striking her body with a closed fist. 720 ILCS 5/12-3.05(a)(1) (West 2022).
¶ 42 Whether an injury constitutes great bodily harm is a question of fact that is determined by
the trier of fact. People v. Crespo, 203 Ill. 2d 335, 344 (2001). “Thus, as long as the evidence was
sufficient to support a finding of great bodily harm, the trial court’s determination will be
affirmed.” People v. Lopez-Bonilla, 2011 IL App (2d) 100688, ¶ 14.
¶ 43 “Bodily harm” requires physical pain or damage to the body, such as lacerations, bruises
or abrasions, whether temporary or permanent. People v. Mandarino, 2013 IL App (1st) 111772, ¶
63. “Great bodily harm” does not lend itself to a precise legal definition but requires proof of an
- 11 -
injury greater and more serious in nature than a simple battery. People v. Thigpen, 2017 IL App
(1st) 153151, ¶ 29. Great bodily harm does not require hospitalization or permanent disability or
disfigurement. People v. Figures, 216 Ill. App. 3d 398, 401 (1991). The question is not what the
victim did or did not do to treat his or her injuries, but what injuries the victim received. Thigpen,
2017 IL App (1st) 153151, ¶ 29.
¶ 44 When determining whether a defendant’s actions caused great bodily harm, direct evidence
of an injury may be considered but is not required. People v. Bishop, 218 Ill. 2d 232, 250 (2006).
Instead, “the trier of fact may infer injury based on circumstantial evidence in light of common
experience.” Id. In doing so, the trier of fact may consider the description of the attack and of the
victim’s injuries to reasonably conclude that the cumulative evidence supported the finding of
great bodily harm. Lopez-Bonilla, 2011 IL App (2d) 100688, ¶ 19. A physical beating may qualify
as conduct that could cause great bodily harm. People v. Kinnerson, 2020 IL App (4th) 170650, ¶
70.
¶ 45 The lack of medical testimony regarding the severity or permanency of the victim’s injuries
does not preclude a trier of fact from finding great bodily harm. People v. Cisneros, 2013 IL App
(3d) 110851, ¶ 21. “Generally, it is not necessary to present expert testimony on the issue of
causation when the relationship between cause and effect is readily apparent based on common
knowledge and experience.” People v. Steele, 2014 IL App (1st) 121452, ¶ 31. The testimony of a
single witness is sufficient to sustain a conviction where it is positive and credible, even when it is
contradicted by the defendant. People v. Gray, 2017 IL 120958, ¶ 36.
¶ 46 Here, viewed in the light most favorable to the State, the evidence was sufficient for the
trial court to conclude that Boston-Turnipseed suffered great bodily harm. Boston-Turnipseed
testified about the details of defendant’s attack. Defendant struck Boston-Turnipseed in the face
- 12 -
with a fist, then began swinging both fists, hitting Boston-Turnipseed “probably” more than once.
Boston-Turnipseed testified that while defending herself, she pulled defendant’s hair as defendant
rushed at her, causing Boston-Turnipseed to fall backwards and hit her head on a steel and glass
door. Her body then fell hard onto the floor. Boston-Turnipseed’s testimony was corroborated by
Hudson, who testified that she saw defendant punch Boston-Turnipseed in the face with a closed
fist about 10 times, and saw Boston-Turnipseed’s head get pushed against a glass window during
the attack. Further corroboration came from defendant’s testimony that she was several inches
taller than Boston-Turnipseed, and that the height and weight of her body pushed Boston-
Turnipseed backwards, causing her to fall and hit her head.
¶ 47 Boston-Turnipseed further testified that, following defendant’s attack, she needed help
from others to rise from the floor and immediately felt pain in her right knee, neck, left shoulder,
and right thumb. She was transported by ambulance to the hospital where she had x-rays taken and
was treated for a concussion. Photographs admitted into evidence showed Boston-Turnipseed
sitting in a wheelchair in the hospital wearing a neck brace, thereby corroborating her testimony.
¶ 48 Boston-Turnipseed explained that she awoke the next day with her entire body in pain, and
she took three baths a day with Epsom salt. Days later, she saw her primary care doctor who
ordered MRIs. Boston-Turnipseed testified that the MRIs showed that, due to defendant’s actions,
she sustained three bulging discs in her neck, a contusion to her thumb, a rotator tear in her left
shoulder, and a torn meniscus in her right knee.
¶ 49 Boston-Turnipseed also testified that prior to defendant’s attack, she saw her doctor on a
regular basis and had never been treated for a concussion, nor did she have a tear in her shoulder
or a torn meniscus in her right knee. These were “new” injuries that did not exist prior to
- 13 -
defendant’s attack. As of the date of trial, April 23, 2025, more than 1½ years after the incident,
Boston-Turnipseed was unable to return to work and remained on unpaid medical leave.
¶ 50 The trial court found that the testimony from Boston-Turnipseed and Hudson was clear,
credible, and corroborated by the testimony of the other witnesses, the photographs of Boston-
Turnipseed sitting in a wheelchair in the hospital wearing a neck brace, and the videos depicting
defendant’s aggressive actions inside the post office. The court correctly noted that great bodily
harm must consist of more than a bruise or pain and found that Boston-Turnipseed’s explanation
of how she was injured and the injuries she sustained established that she suffered injuries that
were “beyond pain.” The court further stated that the evidence that Boston-Turnipseed was
attacked, fell, and hit her head against glass supported its conclusion that she sustained great bodily
harm.
¶ 51 The record thus reveals that the trial court’s finding that Boston-Turnipseed suffered great
bodily harm was supported by evidence that she sustained multiple injuries more serious than mere
bruises or abrasions. Thigpen, 2017 IL App (1st) 153151, ¶ 29. As the trier of fact, it was the trial
court’s duty to determine whether Boston-Turnipseed’s injuries constituted great bodily harm.
Crespo, 203 Ill. 2d at 344. Based on this record, we find no reason to disturb the trial court’s ruling.
Lopez-Bonilla, 2011 IL App (2d) 100688, ¶ 14.
¶ 52 In reaching this conclusion, we find no merit to defendant’s assertion that the State was
required to present medical records or expert testimony to corroborate Boston-Turnipseed’s
“inadmissible” lay opinion testimony regarding her medical diagnoses. In her briefs, defendant
repeatedly characterized Boston-Turnipseed’s testimony as “inadmissible,” yet she has raised no
argument on appeal challenging the admissibility of the testimony or claiming that the trial court
abused its discretion when it admitted the testimony. Instead, defendant merely asserts in a
- 14 -
conclusory manner that Boston-Turnipseed was “incompetent to testify” and that her testimony
was “inadmissible” without any argument in support of her claim.
¶ 53 The State argues that defendant forfeited any challenge to the admissibility of Boston-
Turnipseed’s testimony. We agree. Illinois Supreme Court Rule 341(h)(7) (eff. Oct. 1, 2020) states
that an argument on appeal “shall contain the contentions of the appellant and the reasons therefor,”
supported by citations to legal authority. The rule further states, “[p]oints not argued are forfeited
and shall not be raised in the reply brief, in oral argument, or on petition for rehearing.” Id.
¶ 54 Here, defendant failed to present an argument challenging the admissibility of Boston-
Turnipseed’s testimony. We therefore find that any assertion by defendant that such testimony was
“inadmissible” or “incompetent” is forfeited.
¶ 55 The record thereby demonstrates that the trial court could reasonably find that defendant’s
actions caused Boston-Turnipseed to be treated for a concussion and placed in a neck brace at the
hospital. The court could also reasonably conclude that defendant’s attack caused the injuries that
were revealed days later in the MRIs. Thus, it was not necessary for the State to present expert
testimony to corroborate Boston-Turnipseed’s testimony or establish causation. Steele, 2014 IL
App (1st) 121452, ¶ 31.
¶ 56 We find defendant’s analogy to Steele unpersuasive. In Steele, the evidence showed that
the victim was merely treated for abrasions on his knees and elbow, which did not constitute great
bodily harm, and he was released from the hospital within a few hours. Steele, 2014 IL App (1st)
121452, ¶ 29. At trial, the victim testified that he was subsequently diagnosed with torn ligaments
in both knees and torn ligaments and bone fragments in his right shoulder, which was not supported
by any other evidence. Id. ¶ 30. At sentencing, the victim explained that he had subsequently
visited another doctor who diagnosed him with the torn ligaments. Id. ¶ 31. The appellate court
- 15 -
held that the State failed to prove that the victim suffered great bodily harm because the cause of
the torn ligaments was not readily apparent based on common knowledge and experience, and
thus, expert testimony was required to establish that the incident with the defendant caused the
torn ligaments. Id.
¶ 57 Here, as discussed, Boston-Turnipseed was treated for a more severe injury than a mere
bruise or abrasion at the hospital, and the evidence showed that her injuries were caused by
defendant’s attack. Accordingly, we conclude that the State proved beyond a reasonable doubt that
Boston-Turnipseed suffered great bodily harm.
¶ 58 III. CONCLUSION
¶ 59 For these reasons, we affirm the judgment of the circuit court of Cook County.
¶ 60 Affirmed.
- 16 -