Background
Lamar M. Meakens was tried without a jury on two counts of reckless discharge of a firearm and six counts of unlawful use of a weapon by a felon (UUWF). The charges arose from two late-night shootings near a Carol Stream apartment complex and Community Park in November 2020. Surveillance video showed a small black SUV at the location on both dates and a hooded driver exiting the vehicle and firing multiple shots.
Police later connected Meakens to a black Chevy Trax matching the SUV and to an apartment where his girlfriend lived. A search of the apartment found four firearms, ammunition, and items tied to Meakens in a shared bedroom closet. Ballistics linked two recovered firearms to shell casings from the shootings, and DNA testing found profiles consistent with Meakens on all four weapons. The trial court convicted him of the firearm offenses, acquitted him of cocaine possession, and imposed concurrent five- and ten-year prison terms.
The Court’s Holding
The appellate court affirmed. Viewing the evidence in the State’s favor, it held that a rational factfinder could conclude beyond a reasonable doubt that Meakens was the shooter and constructively possessed the firearms. The court relied on the matching SUV, Meakens’s access to it and the apartment, the firearms’ location among items associated with him, DNA evidence, ballistics evidence, and the phone evidence. It deferred to the trial court’s credibility determinations rejecting the defense theory that other men possessed the weapons.
The court also held that firing multiple rounds toward a large park surrounded by apartments in a densely populated area supported reckless-discharge convictions. Actual injury or a shot fired directly at a person was unnecessary; the evidence supported a finding that people in the area were endangered. Finally, following its prior decision in People v. Travis, the court rejected Meakens’s facial constitutional challenge to Illinois’s UUWF statute under both the federal and Illinois constitutions.
Key Takeaways
- Circumstantial evidence, taken as a whole, supported identifying Meakens as the shooter and proving constructive firearm possession.
- Reckless discharge may be proved by gunfire that endangers people in a populated area, without proof of actual injury or that a person was directly targeted.
- Illinois’s UUWF statute remains facially constitutional under the Second Amendment and the Illinois Constitution.
Why It Matters
The decision illustrates the breadth of evidence that can support firearm convictions: vehicle access, residence and closet access, DNA, ballistics, phone data, and surveillance footage collectively may suffice even without a direct eyewitness identification.
The order also reaffirms the Third District’s post-Bruen view that Illinois may disarm convicted felons under the UUWF statute. As a Rule 23 order, however, it is nonprecedential except as Illinois Supreme Court Rule 23(e)(1) permits.