People v. Steffens

In People v. Steffens, 131 Ill. App. 3d 141, 475 N.E.2d 606, 86 Ill. Dec. 392 (1985), the defendant and the eventual murder victim "had a verbal altercation regarding the speed of the defendant's car" outside the victim's home. Steffens, 131 Ill. App. 3d at 142. After the altercation, the defendant drove away, and the victim entered his house. Steffens, 131 Ill. App. 3d at 142-43. However, the defendant later returned, and the victim and several members of his family went outside. Steffens, 131 Ill. App. 3d at 143. Though there was some conflict in the testimony, it generally showed that, after a short confrontation, the victim started to walk away from the defendant's car and the defendant accelerated, swerved toward the victim, hit the victim, and dragged him under the car for an appreciable distance (the victim died as a result). See Steffens, 131 Ill. App. 3d at 143-45. The trial court imposed a 30-year sentence (the midpoint of the then applicable 20- to 40-year range). Steffens, 131 Ill. App. 3d at 151. The appellate court reduced the sentence to 20 years. It reasoned as follows: "In the present case, the offense was not a calculated murder. The confrontation between the defendant and the victim was initiated by the victim, and, even though the defendant returned to the scene apparently to cause some sort of trouble, the murder itself was the result of a sudden escalation of the encounter between the defendant and the victim's family. We particularly note the short period of time which elapsed, and, taken in context, the offense did not approach a premeditated attack." Steffens, 131 Ill. App. 3d at 152. The court also noted the defendant's rehabilitative potential based on his youth (he was 16 at the time of the offense), his desire to continue his education, and his lack of a violent criminal history. Steffens, 131 Ill. App. 3d at 152-53.