Kevion Mataz Fields v. Illinois

The Sixth Amendment of the Constitution holds that every accused has the right “to be confronted with the witnesses against him.” U.S. Const. amend. VI (“Confrontation Clause”); see also Crawford v. Washington, 541 U.S. 36, 50 (2004) (“the principal evil at which the Confrontation Clause was directed” was the use of “ex parte examinations as evidence against the accused”). It is thus fundamentally antithetical to the tenets of the United States Constitution to deny a criminal defendant the opportunity to confront his accusers in court. But lower courts have historically disagreed over the extent of the Confrontation Clause’s protections. Indeed, in People v. Fields, 2026 IL App (4th) 4250151-U, the Illinois Fourth District Appellate Court confoundingly concluded that a witness’s accusations, if spoken via excited utterances, do not implicate the Confrontation Clause. This holding undermines both the sanctity of the Constitution’s promises and this Court’s previous understandings of the Confrontation Clause’s reach. Specifically, in this case, the complaining witness implicated defendant Kevion Mataz Fields in a videotaped statement while police officers took detailed notes. But the complaining witness was not called to testify, and Fields never had the chance to cross-examine her. Her statements were nonetheless admitted and considered substantively as “excited utterances,” and the trial judge’s decision to admit and consider these statements was affirmed on direct appeal, under the rationale that her “excited utterances” were necessarily spoken during the course of an ongoing emergency. People v. Fields, 2026 IL App (4th) 4250151-U, ¶¶28, 33-35, 38. As such, the multi-fold question brought up by this decision and presented for review here is 1) whether the complaining witness’s excited utterances were necessarily spoken during a concurrent ongoing emergency; and 2) whether the alleged existence of a concurrent ongoing emergency necessarily rendered this complaining witness’s excited statements non-testimonial and admissible – even without affording Fields a chance at confrontation – or if her statements were instead testimonial in nature because the crime was already over and the police were taking detailed notes about names, addresses, and workplaces.