People v. Sanders

NOTICE 2026 IL App (5th) 250541-U NOTICE Decision filed 10/20/26. The This order was filed under text of this decision may be NO. 5-25-0541 Supreme Court Rule 23 and is changed or corrected prior to not precedent except in the the filing of a Petition for IN THE limited circumstances allowed Rehearing or the disposition of under Rule 23(e)(1). the same. APPELLATE COURT OF ILLINOIS FIFTH DISTRICT ______________________________________________________________________________ THE PEOPLE OF THE STATE OF ILLINOIS, ) Appeal from the ) Circuit Court of Plaintiff-Appellee, ) Edgar County. ) v. ) No. 21-CF-70 ) STEFANIE SANDERS, ) Honorable ) Charles D. Mockbee IV, Defendant-Appellant. ) Judge, presiding. ______________________________________________________________________________ JUSTICE BARBERIS delivered the judgment of the court. Justices Boie and Hackett concurred in the judgment. ORDER ¶1 Held: We affirm defendant’s 12-year sentence where the sentence was statutorily authorized and not an abuse of discretion. ¶2 Defendant, Stefanie Sanders, pled guilty to two counts of involuntary manslaughter (720 ILCS 5/9-3(a) (West 2022)) and one count of endangering the health or life of a child (id. § 12C- 5(a)(1)). The Edgar County circuit court sentenced her to concurrent terms of 12 years’ imprisonment on each involuntary manslaughter count and a concurrent 364-day term on the child- endangerment count. Defendant appeals, arguing the sentence is excessive, because the circuit court placed undue emphasis on deterrence despite the unintentional nature of her conduct. She further contends that the court failed to adequately consider her mental health and addiction struggles and her subsequent, meaningful rehabilitation. For the following reasons, we affirm. 1 ¶3 I. BACKGROUND ¶4 On May 23, 2021, the State charged defendant by information, with two counts of first degree felony murder (id. § 9-1(a)); two counts of reckless involuntary manslaughter (id. § 9-3(a)); aggravated arson (id. § 20-1.1); and residential arson (id. § 20-1(b)). The State alleged that defendant started a fire at her residence causing the deaths of her infant daughter, N.P., and boyfriend, Michael Phipps. Nearly two years later, on May 17, 2023, defendant was charged with two additional counts of first degree murder (id. § 9-1(a)(2)). On March 11, 2025, the State charged defendant with two counts of involuntary manslaughter (id. § 9-3(a)) and one count of endangering the health or life of a child (id. § 12C-5(a)(1)). Defendant remained released on bond for nearly four years. ¶5 On March 21, 2025, defendant pleaded guilty to the two counts of involuntary manslaughter, both Class 2 felonies, and the one count of endangering the health or life of a child, a Class A misdemeanor. In exchange for her guilty plea, the State agreed to dismiss the remaining charges. There was no agreement as to defendant’s sentence. The circuit court admonished defendant of the rights she was giving up by pleading guilty. The court also advised defendant that the sentencing range for the Class 2 felonies was between 3 to 14 years in prison. Defendant indicated that she understood and wished to plead guilty. ¶6 The State provided the following factual basis for the guilty plea. On March 1, 2021, in the early morning hours, first responders were dispatched to a residence in Vermilion, Illinois, after receiving reports of a house fire. When they arrived, the residence was engulfed in flames. Defendant was outside the residence with her two children, three-year-old J.S. and six-year-old D.M. Sanders’s boyfriend, Michael Phipps, and the couple’s infant child, N.P., remained inside. Phipps and N.P. were later found deceased in the master bedroom. 2 ¶7 Investigators determined that the fire originated inside the bathroom, although they were unable to determine its cause. During an investigative interview, defendant stated that she and Phipps had been engaged in a verbal dispute throughout most of the day. She also stated that she had been reckless in her thoughts and actions, had experienced suicidal thoughts earlier that day, and did not believe she was in the right state of mind to care for the children. According to defendant, Phipps came home in the early morning hours of March 1, 2021, the two smoked methamphetamine in the bathroom while the children were elsewhere in the residence. While they were in the bathroom, some toilet paper accidentally caught fire. Defendant stated that she and Phipps believed they had extinguished the fire. Afterward, they went outside, where their verbal dispute continued. They then heard glass break and noticed that the residence was on fire. Investigators subsequently determined that the fire had apparently rekindled. ¶8 Defendant and Phipps both reentered the residence. Defendant located D.M. and J.S. in their bedroom and helped them escape through a window. D.M. sustained severe burns over much of her body and required ongoing medical treatment. Phipps entered the master bedroom in an attempt to rescue N.P. but was unable to do so because of the smoke. A forensic pathologist determined that both Phipps and N.P. died from thermal injuries and carbon monoxide inhalation. The circuit court found the State’s factual basis sufficient and accepted defendant’s plea. ¶9 A presentence investigation report (PSI) was filed on May 12, 2025. The PSI reflected defendant’s history of daily methamphetamine use, prior charges for domestic battery and battery, and a subsequent offense for unlawful delivery of methamphetamine committed approximately two months after the fire. Defendant reported that she stopped using methamphetamine and began participating in counseling in 2023. At the time of the PSI, defendant had been married for nearly 3 two years and was pregnant. She reported having two children: D.M., who lived with her father, and J.S., who lived with defendant’s cousin. ¶ 10 On May 22, 2025, the circuit court held a sentencing hearing. Defendant reported continued sobriety and participation in sobriety groups and counseling. The court heard testimony from Master Sergeant Rossiter, who was assigned to investigate the fire. Rossiter testified regarding text and Facebook messages recovered from defendant’s phone leading up to the house fire. Approximately seven hours before the fire, Sanders messaged a friend, “I am burning the f****** house,” and, “I am f****** leaving the f****** house. I am going down with it. I’m going to take me and every f****** thing down with it.” Approximately three hours before the fire, defendant wrote to a friend, “[T]he last two times we’ve gotten into it we [got] physical and I tried to light the house on fire.” Other messages from the hours and days preceding the fire reflected defendant’s belief that she was suffering from postpartum depression, her fear that she might hurt someone— including one of her children—and her statements that she was going into “psycho mode.” Defendant repeatedly expressed anger and frustration toward Phipps, accusing him of cheating and failing to help her. In other messages, defendant described physical abuse by Phipps and acknowledged, “yeah, I try to set the house on fire and everything with everyone in it even the roommates we had.” In the hours immediately preceding the fire, defendant repeatedly called and messaged Phipps, threatened to leave him, pleaded for help, and stated that she could not handle the situation and was afraid she would become angry and hurt someone. ¶ 11 The circuit court also heard testimony from a Department of Children and Family Services (DCFS) caseworker who had met with defendant monthly for approximately two years. The caseworker testified regarding defendant’s supervised visits with J.S. Although the visits were temporarily suspended following threatening text messages in September 2021 they later resumed 4 without further problems. Since April 2022 defendant had been permitted one hour of supervised visitation with J.S. each week at a DCFS office. The caseworker testified that the visits remained supervised based on a psychological recommendation and ongoing concerns regarding defendant’s progress in therapy and psychiatric treatment. Defendant no longer had visitation with her daughter, D.M. The caseworker also described defendant’s current marriage as unstable and testified that defendant had demonstrated little to no remorse regarding the house fire during their meetings. ¶ 12 The circuit court also received victim-impact statements, including a letter from D.M.’s family describing the extent of her injuries and their continuing impact. D.M. was six years old when approximately 47% of her body was burned in the fire, including her head, back, both arms, and portions of her chest. Her right arm sustained near-fourth-degree burns, resulting in significant muscle damage and permanent loss of function. Following the fire, D.M. had to relearn basic functions, including walking, eating, and using the bathroom. Because of burns to her throat, she was unable to eat solid food for an extended period and required a feeding tube. She underwent several major surgeries, numerous therapy sessions, and continues to require extensive medical treatment. Her family reported that she will require ongoing treatment throughout her childhood and until she has finished growing. ¶ 13 During her statement in allocution, defendant described a history of physical and sexual abuse and acknowledged her own failures. She emphasized her rehabilitation following the fire, including steady employment, participation in sobriety groups and counseling, and her progression to a general-manager position. She also described her stable housing, remarriage, more than three years of sobriety, and continued supervised visits with J.S. without cancellations. Defendant expressed the heartbreak of losing N.P. and asked the court for leniency. 5 ¶ 14 The State argued at the hearing that the aggravating factors substantially outweighed the mitigating factors and urged the court to impose the maximum sentence of 14 years on each involuntary-manslaughter count, to run concurrently, as well as a judgment of conviction on the child-endangerment count. The State emphasized the serious and lasting physical and psychological harm suffered by D.M. and J.S., as well as the deaths of Phipps and the infant, N.P. It also pointed to defendant’s criminal history, including a subsequent conviction for unlawful delivery of methamphetamine and prior battery offenses. ¶ 15 The State further argued that deterrence was particularly important because defendant’s conduct was not an isolated reckless act, but the culmination of repeated reckless behavior, including prior incidents involving the children and defendant’s own statements in the days and hours preceding the fire. The State acknowledged her history of addiction and trauma but argued that those circumstances did not excuse her conduct. It maintained that probation would fail to adequately reflect the seriousness of the offenses or serve the statutory purposes of sentencing, particularly because defendant had already been participating in counseling and classes without the supervision of probation. ¶ 16 The State also urged the circuit court to give little weight to defendant’s pregnancy and rehabilitation efforts as mitigating factors. It relied on the DCFS caseworker’s testimony that defendant had demonstrated little remorse during approximately two years of meetings. Ultimately, the State characterized the case as an exceptionally serious instance of involuntary manslaughter and argued that a substantial term of imprisonment was necessary to hold defendant accountable and deter similarly reckless conduct. ¶ 17 The defense argued that probation was an available and appropriate sentence because the statutory sentencing range for involuntary manslaughter permits both imprisonment and probation. 6 The defense maintained that imprisonment was not necessary to protect the public and that probation would not depreciate the seriousness of her conduct or be inconsistent with the ends of justice. ¶ 18 The defense emphasized defendant’s mental health and substance abuse struggles at the time of the offenses, including what counsel characterized as undiagnosed postpartum depression. The defense further emphasized defendant’s rehabilitation since the offenses. According to counsel, defendant had remained compliant with probation following her subsequent methamphetamine conviction, consistently passed drug tests, maintained sobriety and substance abuse treatment, and continued helping others struggling with addiction. She had also remained compliant with psychiatric treatment and counseling, maintained steady employment for more than two years, and advanced to an office-manager position. ¶ 19 The defense identified several statutory mitigating factors, arguing that defendant did not contemplate that her reckless conduct would cause or threaten serious physical harm. It also emphasized factors concerning the unlikelihood that the circumstances leading to the offenses would recur, defendant’s character and attitude indicating that she was unlikely to commit another crime, and her demonstrated ability to comply with probation. Counsel argued that defendant’s successful compliance with probation over the preceding two years provided concrete evidence that she would comply with any sentence of probation. ¶ 20 The defense also asked the circuit court to consider defendant’s high-risk pregnancy and the statutory mitigating factor concerning her medical condition. Counsel further argued that the court could consider evidence that defendant was suffering from undiagnosed or untreated postpartum depression or postpartum psychosis at the time of the offenses. Finally, the defense emphasized the unique circumstances of the case, noting that defendant lost both her infant child 7 and Phipps, the person with whom she had expected to spend her life. Counsel argued that defendant would continue to live with the consequences of the fire and the loss of her family regardless of the sentence imposed. ¶ 21 Following the parties’ arguments, the circuit court stated that it considered the factual basis, PSI, evidence in aggravation and mitigation, and defendant’s allocution before determining that a sentence of imprisonment was warranted. It acknowledged defendant’s prior successful performance on probation, pregnancy, potential hardship to dependents, rehabilitation efforts, and the unusual circumstances of the case, but gave little weight to the evidence concerning postpartum depression because the defense presented insufficient supporting evidence. ¶ 22 The circuit court placed significant weight on defendant’s criminal history and the need for deterrence, emphasizing the devastating and unique nature of the offenses, which resulted in two deaths and serious physical and psychological harm to others. Although the court recognized that probation was available and that a prison sentence was not necessary to protect the public, it concluded that probation would depreciate the seriousness of defendant’s conduct and be inconsistent with the ends of justice. The court therefore sentenced defendant to concurrent terms of 12 years’ imprisonment on the two involuntary-manslaughter counts and 364 days on the misdemeanor child-endangerment count, with credit for 107 days served. Defendant was eligible for day-for-day credit on the involuntary manslaughter sentences. ¶ 23 Defendant filed a motion to reconsider sentence, arguing that the circuit court had failed to give adequate consideration to mitigating factors and had improperly emphasized D.M.’s injuries. She requested probation or, alternatively, a sentence near the statutory minimum. The court denied the motion, reaffirming that it had considered the applicable aggravating and mitigating factors. Defendant timely appealed. 8 ¶ 24 II. ANALYSIS ¶ 25 Defendant argues that her 12-year sentence is excessive because the circuit court placed undue emphasis on deterrence despite the unintentional nature of her conduct. She further contends that the court failed to adequately consider her mental health and addiction struggles and her subsequent, meaningful rehabilitation. ¶ 26 The Illinois Constitution provides that “[a]ll penalties shall be determined both according to the seriousness of the offense and with the objective of restoring the offender to useful citizenship.” Ill. Const. 1970, art. I, § 11. “A reviewing court gives substantial deference to the [circuit] court’s sentencing decision because the trial judge, having observed the defendant and the proceedings, is in a much better position to consider factors such as the defendant’s credibility, demeanor, moral character, mentality, environment, habits, and age.” People v. Snyder, 2011 IL 111382, ¶ 36. Accordingly, a reviewing court will not reverse a circuit court’s sentencing decision merely because it would have weighed these factors differently. People v. Musgrave, 2019 IL App (4th) 170106, ¶ 56. A reviewing court instead reviews the sentencing determination of the circuit court for an abuse of discretion. People v. Stacey, 193 Ill. 2d 203, 209 (2000). A sentence imposed within the applicable sentencing range is presumptively valid, and a reviewing court will not disturb the court’s evaluation of proper sentencing factors absent an abuse of discretion. People v. Sauseda, 2016 IL App (1st) 140134, ¶ 12. “A [circuit] court’s sentence is an abuse of discretion if it is greatly at odds with the spirit and purpose of the law or is manifestly disproportionate to the nature of the offense.” Musgrave, 2019 IL App (4th) 170106, ¶ 56. Although a reviewing court has the power to reduce or alter a sentence, this power should be exercised cautiously and sparingly. People v. Alexander, 239 Ill. 2d 205, 212 (2010). 9 ¶ 27 Here, defendant pled guilty to two counts of involuntary manslaughter, which is punishable by 3 to 14 years in prison or probation. 720 ILCS 5/9-3(f) (West 2022). Defendant was sentenced to 12 years in prison—a sentence that fell within the applicable sentencing range and is presumptively valid. See Sauseda, 2016 IL App (1st) 140134, ¶ 12. ¶ 28 The record further demonstrates that the circuit court adequately considered the relevant aggravating and mitigating factors. Before imposing the sentence, the court expressly stated that it had considered the factual basis, the PSI and supplemental materials, the evidence presented at the sentencing hearing, the parties’ arguments, defendant’s statement in allocution, and the statutory factors in aggravation and mitigation. The court acknowledged defendant’s successful performance on probation following her subsequent methamphetamine conviction, her pregnancy, potential hardship to her dependents, and the rehabilitation efforts reflected in the record. The court also considered defendant’s claim that she was suffering from postpartum depression at the time of the offense but assigned that factor little weight because the defense had presented insufficient evidence to support it. ¶ 29 The circuit court likewise provided a reasoned basis for rejecting probation. Although it recognized that probation was legally available and expressly found that imprisonment was not necessary to protect the public, it concluded that probation would “deprecate the seriousness of the offender’s conduct” and be “inconsistent with the ends of justice.” In reaching that conclusion, the court emphasized that defendant’s conduct—the use of methamphetamine in a bathroom that led to a fire—resulted in the deaths of two people and severe physical and psychological harm to others. The court also considered the unusual and devastating circumstances of the case and the need to deter similar conduct. 10 ¶ 30 Defendant takes particular issue with the circuit court’s emphasis on deterrence. The record reflects that the court returned to deterrence several times when explaining its sentence, stating that the circumstances of the case “keep[ ] me going back to the idea of deterrence” and that it hoped the sentence would prevent similar conduct in the future. Defendant relies on People v. Martin, 119 Ill. 2d 453 (1988), in support of her argument that deterrence has limited applicability where the underlying conduct was unintentional. ¶ 31 Martin is distinguishable, however. Unlike in Martin, the circuit court here did not impose the statutory maximum sentence; rather, it imposed 12 years of a possible 3-to-14-year sentence. More importantly, the court did not rely solely on the fact of death in imposing sentence. The record reflects consideration of the multiple and significant harms resulting from defendant’s use of methamphetamine in a home while children were present, including the deaths of two victims and the severe physical and psychological injuries suffered by a surviving child. The court also considered defendant’s criminal history, rehabilitation, pregnancy, potential hardship to her dependents, and claimed postpartum depression, although it assigned varying weight to those factors. As noted, the conduct underlying defendant’s convictions involved the repeated use of methamphetamine in an occupied residence and reckless conduct that resulted in a fire, circumstances the court reasonably considered in assessing the need for deterrence. Thus, unlike Martin, the record here demonstrates that the court considered the full range of aggravating and mitigating circumstances before determining that a substantial but less-than-maximum sentence was warranted. ¶ 32 Nor does the record support defendant’s contention that the court failed to consider the mitigating evidence concerning her mental health, addiction, and rehabilitation. The court expressly acknowledged defendant’s prior successful performance on probation, her pregnancy, 11 and the positive changes she had made since the offense. Defendant reported continued sobriety and participation in sobriety groups and counseling, and she continued to have one hour of supervised visitation with J.S. each week. The court also expressly considered defendant’s claim of postpartum depression but assigned it little weight because the defense presented insufficient evidence supporting that condition. That the court ultimately assigned greater weight to the seriousness of the offenses and the need for deterrence does not establish an abuse of discretion. “The trial court is not required to detail precisely for the record the exact process by which it determined the penalty, nor is it required to articulate consideration of mitigating factors.” People v. Gordon, 2016 IL App (1st) 134004, ¶ 51. The sentencing court is likewise not required to give greater weight to mitigating evidence simply because it was presented. ¶ 33 Defendant’s argument essentially asks this court to reweigh the aggravating and mitigating factors and substitute our judgment for that of the sentencing court. But “[a] defendant’s rehabilitative potential *** is not entitled to greater weight than the seriousness of the offense.” People v. Coleman, 166 Ill. 2d 247, 261 (1995). Because the circuit court adequately considered the appropriate sentencing factors, we may not reweigh those factors on appeal. See Alexander, 239 Ill. 2d at 214-15 (explaining that an appellate court improperly substitutes its judgment for that of the trial court when it would have weighed the sentencing factors differently). ¶ 34 Moreover, the 12-year sentence was two years below the statutory maximum. Given the circumstances of the offenses—including the deaths of Phipps and N.P., the severe and lasting injuries sustained by D.M., defendant’s repeated threats to set the residence on fire, and her subsequent methamphetamine conviction—we cannot say that the sentence was greatly at odds with the spirit and purpose of the law or manifestly disproportionate to the nature of the offenses. We reiterate that sentencing is within the province of the circuit court. People v. Lefler, 2016 IL 12 App (3d) 140293, ¶ 31. “[I]t is equally well-settled that the weight to be assigned to factors in aggravation and mitigation and the balance between those factors are matters within the sentencing court’s discretion.” Id. The record reflects that the circuit court considered the appropriate aggravating and mitigating factors, explained its decision to deny probation, and imposed a sentence within the statutory range. Accordingly, we find no abuse of discretion. ¶ 35 III. CONCLUSION ¶ 36 For the foregoing reasons, we affirm the judgment of the Edgar County circuit court. ¶ 37 Affirmed. 13