transferred intent doctrine in Illinois

2015App. 3d 581, 586 (1988)). 24 No. 1-13-1144 ¶ 60 "Under the doctrine of transferred intent, if a defendant shoots at one person, with the intent to kill, but kills an unintended victim, he may be convicted of the crime of murder for the death of the unintended victim." People v. Thompson, 313 Ill.

2015App. 3d 581, 586 (1988)). ¶ 60 “Under the doctrine of transferred intent, if a defendant shoots at one person, with the intent to kill, but kills an unintended victim, he may be convicted of the crime of murder for the death of the unintended victim.” People v. Thompson, 313 Ill.

2008App. 3d 39, 44 , 291 N.E.2d 523, 527 (1973)(finding, under the doctrine of transferred intent, that the defendant's intent to kill his brother was sufficient to support an aggravated-battery convic- tion for actually harming his ex-wife even though the defendant's ex-wife was not the intended victim).

2008App. 3d 39, 44 , 291 N.E.2d 523, 527 (1973) (finding, under the doctrine of transferred intent, that the defendant’s intent to kill his brother was sufficient to support an aggravated-battery conviction for actually harming his ex-wife even though the defendant’s ex-wife was not the intended victim).

2025The doctrine of transferred intent applies “when a third person is injured as a result of a defendant’s assault upon another person.” People v. Burrage, 269 Ill.

1995The law is well settled that where a person shoots at one with intent to kill and murder, but kills one whom he did not intend to injure, he is not absolved from answering for the crime of murder. ( People v. Marshall (1947), 398 Ill. 256 , 75 N.E.2d 310 .) Moreover, the doctrine of transferred intent is applicable in attempt murder cases. ( See People v. Burrage (1994), 269 Ill.App.3d 67 , 206 Ill.Dec. 450 , 645 N.E.2d 455 ; People v. Humes (1979), 78 Ill.App.3d 255 , 33 Ill.Dec. 797 , 397 N.E.2d 130 ; People v. Swaney *1298 (1971), 2 Ill.App.3d 857 , 276 N.E.2d 346 .) Accordingly, if the evi

2020App. 3d at 1108 (the doctrine of transferred intent has been applied to “attempted murder cases where an unintended victim is injured”); see also People v. Hensley, 2014 IL App (1st) 120802, ¶ 83 (the doctrine of transferred intent applies when an unintended victim is injured); People v. Valentin, 347 Ill.

2015Rather, our review is focused on “whether, after viewing the evidence in the light most favorable to the prosecution, any rational trier of fact could have found the essential elements of the offense beyond a reasonable doubt.” People v. Baskerville, 2012 IL 111056, ¶ 31 . ¶ 83 The doctrine of transferred intent “applies when a third person is injured as a result of a defendant’s assault upon another person.” People v. Valentin, 347 Ill.

2025Under the doctrine of transferred intent, “[w]here someone in the commission of a wrongful act commits another wrong not intended, or where in the execution of an intent to do wrong, an unintended act resulting in a wrong ensued as a natural and probable consequence, the one acting with a wrongful intent is responsible for the unintended wrong.” People v. Psichalinos, 229 Ill.

2009App. 3d 510, 516 (2000); see also People v. Psichalinos, 229 Ill.

2008App. 3d 824, 828 , 370 N.E.2d 145, 147 (1977) - 10 - (affirming conviction for aggravated battery under the transferred-intent doctrine where the shooting of an individual was a natural and probable consequence of the defendant's delib- erate act of firing a cane gun to frighten a crowd); In re Joel L., 345 Ill.

2008App. 3d 824, 828 , 370 N.E.2d 145, 147 (1977) (affirming conviction for aggravated battery under the transferred-intent doctrine where the shooting of an individual was a natural and probable consequence of the defendant’s deliberate act of firing a cane gun to frighten a crowd); In re Joel L., 345 Ill.

2021See People v. Calloway, 2019 IL App (1st) 160983, ¶ 33 (applying sufficiency of the evidence review over the defendant’s argument that de novo review applied where the question presented was “a disputed factual question”). ¶ 30 To establish aggravated battery with a firearm, the State must prove that while “committing a battery, [the defendant] knowingly or intentionally by means of discharging a firearm” caused injury to Hurd. 720 ILCS 5/12-4.2(a)(1) (West 2010). ¶ 31 Defendant argues that because this is a specific intent crime, the State had to prove “not only that [defendant] fired his wea

2020App. 3d at 1108 (the doctrine of transferred intent has been applied to “attempted murder cases where an unintended victim is injured”); see also People v. Hensley, 2014 IL App (1st) 120802, ¶ 83 (the doctrine of transferred intent applies when an unintended victim is injured); People v. Valentin, 347 Ill.

2014As stated earlier, the evidence must be viewed in the light most favorable to the prosecution. ¶ 39 Respondent concedes “[u]nder the doctrine of transferred intent, [respondent] is responsible for causing the physical contact between the chair and Robert McGuire if the chair he threw hit McGuire.” See People v. Dorn, 378 Ill.

2009Illinois has consistently held that, “[ujnder the doctrine of transferred intent, one who does an unlawful act is liable for the natural and probable consequences of such act.” People v. Dorn, 378 Ill.

2008App. 3d 824, 828 , 370 N.E.2d 145, 147 (1977) - 10 - (affirming conviction for aggravated battery under the transferred-intent doctrine where the shooting of an individual was a natural and probable consequence of the defendant's delib- erate act of firing a cane gun to frighten a crowd); In re Joel L., 345 Ill.

2008App. 3d 824, 828 , 370 N.E.2d 145, 147 (1977) (affirming conviction for aggravated battery under the transferred-intent doctrine where the shooting of an individual was a natural and probable consequence of the defendant’s deliberate act of firing a cane gun to frighten a crowd); In re Joel L., 345 Ill.

2003People v. Conley, 306 Ill.

2003The transferred intent doctrine teaches that a "defendant can be convicted of attempted murder of an unintended victim if he shoots at one person with the intent to kill, but injures another; defendant’s intent to kill the intended victim is transferred to the unintended victim." Slip op. at 10, citing People v. Conley , 306 Ill.

2012“Under the doctrine of transferred intent, defendant can be exonerated if he shoots an assailant in self-defense but injures another; defendant’s intent to shoot his assailant in self-defense is transferred to the unintended victim.” People v. Blue, 343 Ill.

2012“Under the doctrine of transferred intent, defendant can be exonerated if he shoots an assailant in self-defense but injures another; defendant’s intent to shoot his assailant in self-defense is transferred to the unintended victim.” People v. Blue, 343 Ill.

1995The law is well settled that where a person shoots at one with intent to kill and murder, but kills one whom he did not intend to injure, he is not absolved from answering for the crime of murder. ( People v. Marshall (1947), 398 Ill. 256 , 75 N.E.2d 310 .) Moreover, the doctrine of transferred intent is applicable in attempt murder cases. ( See People v. Burrage (1994), 269 Ill.App.3d 67 , 206 Ill.Dec. 450 , 645 N.E.2d 455 ; People v. Humes (1979), 78 Ill.App.3d 255 , 33 Ill.Dec. 797 , 397 N.E.2d 130 ; People v. Swaney *1298 (1971), 2 Ill.App.3d 857 , 276 N.E.2d 346 .) Accordingly, if the evi

1995The law is well settled that where a person shoots at one with intent to kill and murder, but kills one whom he did not intend to injure, he is not absolved from answering for the crime of murder. ( People v. Marshall (1947), 398 Ill. 256 , 75 N.E.2d 310 .) Moreover, the doctrine of transferred intent is applicable in attempt murder cases. ( See People v. Burrage (1994), 269 Ill.App.3d 67 , 206 Ill.Dec. 450 , 645 N.E.2d 455 ; People v. Humes (1979), 78 Ill.App.3d 255 , 33 Ill.Dec. 797 , 397 N.E.2d 130 ; People v. Swaney *1298 (1971), 2 Ill.App.3d 857 , 276 N.E.2d 346 .) Accordingly, if the evi

2026See id.

2026People v. Shelton, 293 Ill.

2026The legislature included the doctrine of transferred intent in the Criminal Code by use of the phrase “or another”; that is, a defendant is guilty of murder pursuant to section 9-1(a)(1) if she “ ‘intends to kill or do great bodily harm to that individual or another, or knows that such acts will cause death to that individual or another.’ ” (Emphasis in original.) Id. at 752 (quoting 720 ILCS 5/9-1(a)(1) (West 1994)); see also 720 ILCS Ann. 5/9-1, Committee Comments-1961, at 14 (Smith Hurd 1992) (“ ‘Or another’ recognizes the established principle often described as ‘transferred intent’ ”).

2024Under the transferred intent rule, “where a person shoots at one and in the direction of another, with intent to kill, but kills or injures the other, he may be convicted of the crime of murder or attempted murder of the unintended victim.” People v. Migliore, 170 Ill.

2024See 8 Because we find the evidence sufficient to show defendant’s specific intent to kill Price and Adams, we need not address defendant’s argument that the transferred intent doctrine cannot “save[ ]” his attempted murder convictions. - 20 - No. 1-22-1744 People v. Glasper, 234 Ill. 2d 173, 212 (2009) (State did not shift burden of proof to defendant where it “pointed out that no evidence *** support[ed] defendant’s theory of coercion”). ¶ 63 2.

2022See People v. Homes, 274 Ill.