People v. Williams: Definitional vs. Mandatory Jury Instructions and the Partial Overruling of Warrington

People v. Williams: Definitional vs. Mandatory Jury Instructions and the Partial Overruling of People v. Warrington

I. Introduction

In People v. Williams, 2025 IL 130779 (Ill. Nov. 20, 2025), the Illinois Supreme Court addressed a recurring—and practically important—question in criminal jury instruction law: when can two pattern instructions, one definitional and one setting out the elements for conviction, be said to “conflict” such that their use constitutes plain error?

The defendant, Isaiah J. Williams, was tried in Kendall County for aggravated domestic battery and for threatening a public official under section 12‑9 of the Criminal Code of 2012 (720 ILCS 5/12‑9 (West 2020)). The “public official” was a sworn law enforcement officer, Deputy Nicholas Albarran. Because the alleged victim was an officer, the State had to prove—not only the basic elements of threatening a public official—but also the heightened “unique threat” requirement of section 12‑9(a‑5).

The trial court instructed the jury using the Illinois Pattern Jury Instructions, Criminal (IPI Criminal) Nos. 11.49 and 11.50. IPI 11.49 sets out a general definition of the offense of threatening a public official. IPI 11.50, an issues instruction, lists the propositions the State must prove beyond a reasonable doubt in the particular case, including the special “unique threat” element for threats to officers.

Williams did not object to these instructions at trial, but on appeal he argued that the two pattern instructions were “conflicting” because IPI 11.49 does not mention the “unique threat” requirement, while IPI 11.50 does. He claimed this amounted to reversible plain error, or alternatively ineffective assistance of counsel for failure to object.

The appellate court rejected that argument and expressly declined to follow the Third District’s contrary decision in People v. Warrington, 2014 IL App (3d) 110772. The Supreme Court granted leave to appeal and, in a unanimous opinion by Justice Cunningham, affirmed. In doing so, it clarified the law governing allegedly conflicting instructions, distinguished prior plain-error cases, and explicitly overruled part of Warrington.

II. Summary of the Opinion

The Supreme Court held that:

  • IPI Criminal Nos. 11.49 (definitional) and 11.50 (issues/elements) are complementary, not conflicting, even though only 11.50 contains the officer‑specific “unique threat” requirement (¶¶ 16–17, 23).
  • When read together, as juries are instructed and presumed to do, the instructions fully and accurately informed the jury that the State had to prove the “unique threat” element beyond a reasonable doubt (¶¶ 17, 23).
  • Because there was no instructional error at all, there could be no plain error, and defense counsel was not ineffective for failing to object (¶ 23).
  • The Court distinguished earlier decisions (Jenkins and Hartfield) where truly contradictory mandatory issues instructions created plain error (¶¶ 18–20).
  • The Court expressly overruled People v. Warrington, 2014 IL App (3d) 110772, “on this point”: its holding that the combination of the definitional and issues instructions was legally inconsistent and required reversal (¶ 22).

On that basis, the Court affirmed the appellate court, which in turn had affirmed the circuit court’s judgment (¶¶ 23, 25–26).

III. Factual and Procedural Background

A. The Underlying Incident

On April 29, 2021, Deputy Nicholas Albarran responded to a domestic battery call at the home of Williams and Teresa Sanchez (¶ 3). After speaking with Sanchez, the deputy arrested Williams. During the arrest and transport, Williams:

  • acted “hostile and aggressive” toward the deputy (¶ 5);
  • challenged the deputy to “get physical” and to remove the handcuffs (¶ 5);
  • repeatedly called the deputy a “bitch” (¶ 5);
  • said he would “fuck [the deputy] up” if the handcuffs came off (¶ 5);
  • said he wished the deputy would get shot (¶ 5).

Later, after being booked into the Kendall County Jail, Williams was recorded on another deputy’s body‑worn camera saying that “if he saw [Deputy Albarran] on the street, that he would fucking kill [him], and that he would slash [his] throat if he caught [him] on the street” (¶ 6). Williams admitted at trial that he made this statement (¶ 6).

B. The Charge and the “Unique Threat” Element

Williams was charged with:

  • aggravated domestic battery; and
  • threatening a public official, in violation of 720 ILCS 5/12‑9 (West 2020) (¶ 4).

Section 12‑9(a) defines the offense of threatening a public official generally. For the present case, the crucial parts were:

“(a) A person commits threatening a public official *** when:
(1) that person knowingly delivers or conveys, directly or indirectly, to a public official *** by any means a communication:
(i) containing a threat that would place the public official *** in reasonable apprehension of immediate or future bodily harm, sexual assault, confinement, or restraint; ***
*** and
(2) the threat was conveyed because of the performance or nonperformance of some public duty ***.” (¶ 4)

A “public official” includes “a sworn law enforcement or peace officer” (720 ILCS 5/12‑9(b)(1)) (¶ 4). For threats to officers, however, subsection (a‑5) adds a heightened element:

“[f]or purposes of a threat to a sworn law enforcement officer, the threat must contain specific facts indicative of a unique threat to the person, family or property of the officer and not a generalized threat of harm.” (¶ 4)

Thus, in an officer‑threat case, the State must prove the general elements of section 12‑9(a) plus the “unique threat” requirement of section 12‑9(a‑5).

C. The Jury Instructions at Trial

In closing argument, the State explicitly told the jury that it had to prove the “unique threat” requirement in this case because the victim was a sworn officer, and highlighted Williams’s statement that he would kill the deputy and “slash his throat” if he saw him on the street as satisfying that element (¶ 7).

The court then instructed the jury as follows (in relevant part):

  • IPI Criminal No. 11.49 (Definitional Instruction)
    The court told the jury:
    “A person commits the offense of threatening a public official when he knowingly delivers or conveys, directly or indirectly, to a public official by any means a communication containing a threat that would place the public official in reasonable apprehension of immediate or future bodily harm; and the threat was conveyed because of the performance or nonperformance of some public duty.” (¶ 8)
    This is a general definitional description of the offense.
  • IPI Criminal No. 11.50 (Issues/Elements Instruction)
    The court then gave the issues instruction, which set out five propositions the State had to prove beyond a reasonable doubt, including:
    • a communication containing a threat causing reasonable apprehension of bodily harm;
    • that Albarran was a public official, and Williams knew it;
    • that the threat was because of performance or nonperformance of a public duty; and crucially
    • the Fifth Proposition:
      “That the threat to a sworn law enforcement officer contained specific facts indicative of a unique threat to the sworn law enforcement officer and not a generalized threat of harm.” (¶ 8)
    The instruction concluded with the standard mandatory direction:
    “If you find from your consideration of all the evidence that each one of these propositions has been proved beyond a reasonable doubt, you should find the defendant guilty. If you find from your consideration of all the evidence that any one of these propositions has not been proved beyond a reasonable doubt, you should find the defendant not guilty.” (¶ 8)
  • IPI Criminal No. 11.49A stated that a sworn law enforcement officer is a public official (¶ 8).
  • IPI Criminal No. 1.01 reminded jurors it was their duty to follow all instructions and that they may “not single out certain instructions and disregard others” (¶ 8).

Defense counsel affirmatively stated he had “no objection” to these instructions and did not request any alternative or supplemental instructions (¶ 9). The jury acquitted Williams of aggravated domestic battery but convicted him of threatening a public official (¶ 9). He was sentenced to 18 months’ probation (¶ 9).

D. Appeal and the Conflict-With-IPI Argument

On appeal, Williams argued that:

  • IPI 11.49 (the definitional instruction) omits the “unique threat” element required by section 12‑9(a‑5);
  • IPI 11.50 (the issues instruction) includes that element;
  • the jury could have relied solely on IPI 11.49 to determine the elements of the offense and thus could have convicted him without finding the “unique threat” requirement beyond a reasonable doubt (¶ 10);
  • the two instructions were therefore “conflicting” on an essential element, constituting plain error, or at least ineffective assistance for failure to object (¶¶ 10–11, 13).

The appellate court rejected this, holding that 11.49 and 11.50 are complementary, not conflicting, and declined to follow Warrington (¶ 11). The Supreme Court granted leave to appeal (¶ 12).

IV. Precedents and Authorities Considered

A. General Principles on Jury Instructions

The Court grounded its analysis in several established principles:

  • Purpose of instructions. Jury instructions must give jurors the correct legal principles so they can reach a verdict according to law and evidence (People v. Bannister, 232 Ill. 2d 52, 81 (2008), cited at ¶ 15).
  • Standard for confusion. Instructions should not mislead or confuse, but the test is whether “ordinary persons acting as jurors would fail to understand them,” not whether counsel can imagine a problematic reading (People v. Herron, 215 Ill. 2d 167, 187–88 (2005), cited at ¶ 15).
  • Whole‑package reading. Instructions are read together, not in isolation; the question is whether, when considered as a whole, they “fully and fairly announce the law” (People v. Mohr, 228 Ill. 2d 53, 65 (2008); People v. Parker, 223 Ill. 2d 494, 501 (2006); People v. Housby, 84 Ill. 2d 415, 433–34 (1981), cited at ¶¶ 15, 17).
  • De novo review. Whether instructions accurately convey the law is reviewed de novo (McQueen v. Green, 2022 IL 126666, ¶ 35, cited at ¶ 15).
  • Presumption jurors follow the law. Absent evidence to the contrary, courts presume jurors follow the trial court’s instructions, including directions not to disregard any instruction (People v. Wilmington, 2013 IL 112938, ¶ 49, cited at ¶ 17).

B. Plain Error and Conflicting Instructions: Jenkins and Hartfield

Williams relied heavily on two prior Illinois Supreme Court cases where erroneous instructions were held to be plain error:

  1. People v. Jenkins, 69 Ill. 2d 61 (1977) (¶ 18).

    In Jenkins, the jury was given:

    • one mandatory issues instruction telling jurors to find the defendant guilty of attempted murder if the State proved two listed propositions; and
    • a second, separate mandatory issues instruction telling jurors to find him guilty if the State proved three propositions.

    These instructions were both “mandatory” and “self‑contained,” yet they contradicted each other as to the number of elements the State must prove (¶ 18). The Court held that this prevented the jury from performing its constitutional function and constituted plain error (¶ 18).

  2. People v. Hartfield, 2022 IL 126729 (¶ 19).

    In Hartfield, the jury was instructed:

    • in one instruction, that it could convict the defendant of aggravated discharge of a firearm in the direction of a peace officer if the officer was in fact in the direction of the shots; but
    • in another, that its determination of guilt must be based on whether the officer may have been in the direction of the discharge (¶ 19).

    These were both mandatory instructions on the same essential element (direction of discharge) and gave conflicting legal commands. Because it was impossible to know which the jury followed, the Court held that the error was plain and reversible (¶ 19, ¶ 61 in Hartfield).

These cases stand for the proposition that truly contradictory mandatory issues instructions on an essential element of the offense constitute plain error.

C. People v. Warrington, 2014 IL App (3d) 110772

The Third District’s decision in Warrington was central to the controversy and is directly addressed—and partially overruled—in Williams (¶¶ 11, 21–22).

In Warrington:

  • The defendant was charged with threatening a public official, a police officer (¶ 21).
  • The trial court gave two instructions:
    • People’s Instruction No. 12, modeled on IPI 11.50, as the issues instruction. It explicitly required that the officer be placed in “reasonable apprehension” of harm (¶ 21).
    • People’s Instruction No. 10, modeled on IPI 11.49, as the definitional instruction, which did not contain the “reasonable apprehension” language and did not direct a finding of guilt or innocence (¶ 21).
  • The Third District held that a “simple comparison” showed these instructions to be “inconsistent” and that giving them together was plain error because “conflicting instructions cannot be deemed harmless” (¶ 21, quoting Warrington ¶ 30).

In Williams, the Supreme Court rejects that core holding, concluding that the definitional instruction did not contradict the issues instruction because:

  • only the issues instruction directed the jury to decide guilt based on a set of propositions, and
  • the definitional instruction simply described the offense in general terms without negating any element listed in the issues instruction (¶ 22).

The Court therefore “expressly overruled” Warrington “on this point” (¶ 22), while explicitly leaving untouched its alternative holding that the jury in that case was never instructed at all on the statutory “unique threat” requirement (¶ 22 n.1).

V. The Court’s Legal Reasoning

A. The Central Question: Are IPI 11.49 and 11.50 Conflicting?

Williams’s argument assumes:

  1. that IPI 11.49 and IPI 11.50 are “inconsistent on an essential element” (the “unique threat” requirement); and
  2. that the jury might have relied solely on IPI 11.49 to identify the elements of the offense and thus convicted him without finding the “unique threat” element (¶ 16).

The Supreme Court rejects both premises.

B. Reading Instructions Together and Presuming Juror Compliance

The Court stresses two key interpretive principles:

  • Instructions are not read in isolation.
    Citing Parker and Housby, the Court reiterates that “jury instructions are not read in isolation; they are construed as a whole” (¶ 17).
  • Jurors are presumed to follow instructions.
    The jury here was specifically instructed via IPI 1.01 not to single out or disregard any instruction, and under Wilmington courts presume jurors follow such directions (¶ 17).

Applying these principles, the Court holds that:

“No reasonable juror in this case could have believed that IPI Criminal No. 11.49 by itself governed this case or that IPI Criminal No. 11.50 could simply be disregarded.” (¶ 17)

And further:

“IPI Criminal No. 11.50 unambiguously told the jury that the State had to prove the ‘unique threat’ requirement beyond a reasonable doubt to secure a conviction for threatening a public official, and nothing in IPI Criminal No. 11.49 negated that proposition.” (¶ 17)

Thus, when read together, the instructions “accurately set forth the applicable law,” and “the jury in this case could not have convicted Williams without finding the ‘unique threat’ requirement beyond a reasonable doubt” (¶ 17).

C. Distinguishing Jenkins and Hartfield

The Court then contrasts this case with Jenkins and Hartfield:

  • In Jenkins, both instructions were mandatory issues instructions. Each told the jury under what conditions it “must” find the defendant guilty, but they stated different legal conditions (¶ 18). That is direct, irreconcilable conflict in the jury’s marching orders.
  • In Hartfield, again, two mandatory instructions used different legal standards (“was in the direction” vs. “may have been in the direction”), both purporting to govern guilt on the same essential element (¶ 19). The jury could not know which legal rule to apply.

By contrast, in Williams:

  • only IPI 11.50 listed the propositions that must be proven and directed the jury to find guilt if those propositions were established (¶ 20);
  • IPI 11.49 did not tell the jury under what circumstances it must convict or acquit but simply provided a general definition of the offense (¶ 20);
  • therefore, there were not “two different, mandatory instructions” on what the jury had to find to convict—instead there was one issues instruction and one definitional instruction (¶ 20).

Because of that structural difference, the Court concludes that this is not a Jenkins/Hartfield-type conflict:

“Consequently, there is no contradiction between the two instructions and the jurors in this case were not forced to pick between inconsistent legal commands.” (¶ 20)

D. Overruling Warrington on Conflicting-Instruction Theory

The Court then squarely addresses Warrington, which had treated the combination of a definitional instruction (like IPI 11.49) and an issues instruction (like IPI 11.50) as “inconsistent” and reversible plain error (¶¶ 21–22).

The Supreme Court explains:

  • In Warrington, People’s Instruction No. 12 (issues instruction) directed the jury to find guilt if the State proved certain propositions, including that the officer was placed in “reasonable apprehension” of harm (¶ 21).
  • People’s Instruction No. 10 (definitional) set out a general definition of threatening a public official, without the “reasonable apprehension” phrase (¶ 21).
  • The Third District saw a conflict between these instructions and applied a per se rule that “conflicting instructions cannot be deemed harmless” (¶ 21).

The Supreme Court states this analysis was “incorrect” (¶ 22):

“Only People’s instruction No. 12 directed the jury to find the defendant guilty of threatening a public official based on the State having shown that certain propositions were true. People’s instruction No. 10 contained no such directive, as it set forth only a general definition of the offense. Accordingly, nothing in People’s instruction No. 10 contradicted the legal command given in People’s instruction No. 12, and the jury did not face any confusion regarding what propositions had to be established to find the defendant guilty.” (¶ 22)

Accordingly, the Court “expressly overrule[s]” Warrington “on this point” (¶ 22).

However, the Court is careful to note that Warrington also had a “second, ‘more important’ reason for reversing” the conviction: the trial court there “failed to instruct the jury entirely on the necessity of finding that the defendant had made a ‘unique threat’ to the police officer” (¶ 22 n.1, quoting Warrington ¶ 31). The Supreme Court “express[es] no opinion” on that alternative holding, recognizing that it independently supported reversal in that case (¶ 22 n.1).

This clarification is significant: it preserves the substantive requirement that juries in officer‑threat cases must be instructed on the “unique threat” element, while rejecting the idea that a definitional and issues instruction that do not identically recite every element are per se conflicting.

E. No Instructional Error, Hence No Plain Error or Ineffective Assistance

Having concluded that the instructions here were not conflicting and did fully and fairly convey the law, the Court holds:

  • No error occurred in giving IPI 11.49 and 11.50 together (¶ 23).
  • Because “no error occurred, there was no plain error” (¶ 23). Under Illinois’ plain‑error doctrine, a court first determines whether an error occurred; only then does it consider whether the error is reversible under plain error. Here, the analysis ends at step one.
  • Williams’s ineffective assistance claim fails as well: trial counsel cannot be deficient for failing to object to correct instructions, and there is no prejudice when the underlying objection would have been meritless (¶ 23).

Thus, the conviction and sentence stand.

VI. Impact and Doctrinal Significance

A. Clarifying the Status of IPI Criminal 11.49 and 11.50

The decision has an immediate, practical impact on Illinois criminal practice:

  • Trial courts may confidently continue to use IPI Criminal Nos. 11.49 (definitional) and 11.50 (issues) together in prosecutions for threatening public officials, including sworn law enforcement officers.
  • Defense arguments that these particular pattern instructions are inherently “conflicting” or constitute plain error have been foreclosed by binding Supreme Court authority.
  • The Court implicitly affirms the IPI Committee’s structural approach: a general definitional instruction that omits a special statutory enhancement can coexist with an issues instruction that expressly includes that element.

B. Definitional vs. Mandatory (Issues) Instructions

A broader doctrinal point is the Court’s clear distinction between:

  • Definitional instructions (like IPI 11.49), which:
    • state in general terms what conduct constitutes an offense;
    • do not direct a verdict;
    • do not, by themselves, set the complete checklist of propositions the State must prove in that specific case.
  • Issues (or elements) instructions (like IPI 11.50), which:
    • list the propositions that the State must prove beyond a reasonable doubt in the case at hand;
    • include the special statutory elements applicable to the charged offense as prosecuted;
    • contain a mandatory directive—e.g., if all propositions are proved, “you should find the defendant guilty;” if not, “you should find the defendant not guilty.”

Williams teaches that when assessing alleged “conflicts” in instructions, courts must:

  1. Identify which instructions are mandatory issues instructions that direct how the jury must decide guilt; and
  2. Recognize that definitional instructions that provide general background but do not direct a verdict rarely, by themselves, create a Jenkins/Hartfield-type conflict, unless they explicitly negate or contradict an element in the issues instruction.

This is a narrowing of the doctrine of “conflicting instructions” and a reinforcement of the idea that merely different phrasing or differing levels of detail do not automatically create reversible conflict.

C. Plain Error Doctrine: Threshold Emphasis on Actual Error

Procedurally, the case reinforces the analytical sequence for plain-error review in Illinois:

  1. The reviewing court must first determine whether an error occurred at all.
  2. Only if error is found does the court analyze whether the error is reversible under one of the two plain‑error prongs (closely balanced evidence, or error so serious it affected the fairness of the trial).

In Williams, because the Court found no instructional error, it did not reach the plain‑error prongs (¶ 23). This underscores that not every pattern‑instruction challenge—even when framed as constitutional or structural—passes the threshold of actual legal error.

D. Ineffective Assistance Tied to the Merits of the Objection

The Court’s rejection of the ineffective assistance claim illustrates a routine but important principle: counsel is not ineffective for failing to make a futile objection. Once the Court determined the pattern instructions were proper, counsel’s acquiescence to them could not be deemed deficient performance, nor could there be prejudice (¶ 23).

E. Overruling Warrington and Stabilizing Instructional Law

By expressly overruling Warrington “on this point” (¶ 22), the Court:

  • Eliminates a source of conflict between appellate districts over whether 11.49/11.50‑type combinations are inherently inconsistent.
  • Reaffirms that the IPI framework of paired definitional and issues instructions is generally sound when each is properly tailored to the statute and charge.
  • Signals that future claims of plain error based solely on the coexistence of a general definitional instruction and a more detailed issues instruction are disfavored, absent clear contradictory directives.

At the same time, the Court takes pains not to undermine the substantive requirement that juries in officer‑threat cases be instructed on the “unique threat” element. If a trial court were to omit that element entirely from the issues instruction—as Warrington said occurred there—that would remain potentially reversible error. Williams does not disturb that proposition (¶ 22 n.1).

F. Application to Threats Against Law Enforcement Officers

In the specific context of threats against sworn officers:

  • The State must still prove—and the jury must still be instructed on—the “unique threat” requirement of 720 ILCS 5/12‑9(a‑5).
  • Because IPI 11.50 expressly incorporates that element (as the Fifth Proposition), its use in officer‑threat cases helps ensure compliance with the statute.
  • Defense counsel should focus on whether the issues instruction includes the unique‑threat element (as 11.50 does), not on quibbles about whether the definitional instruction restates it.

Thus, Williams does not water down the substantive protections of section 12‑9(a‑5); it clarifies how those protections are to be encoded in jury instructions without turning every definitional omission into plain error.

VII. Complex Concepts Simplified

A. Pattern Jury Instructions (IPI)

Illinois Pattern Jury Instructions (IPI) are model instructions drafted by a committee, intended to reflect current Illinois law and to promote uniformity and clarity in jury trials. Courts are not legally bound to use them, but they are strongly encouraged to do so. When properly used, they are usually presumed to be correct statements of the law.

Here:

  • IPI Criminal No. 11.49 is a definitional instruction describing, in general terms, the offense of threatening a public official.
  • IPI Criminal No. 11.50 is an issues (elements) instruction that tailors the general definition to the specific case, listing what exactly the State has to prove.

B. Definitional vs. Issues Instructions

To a layperson, the difference can be framed this way:

  • A definitional instruction answers the question: “What is this crime, in general?”
  • An issues instruction answers the question: “In this particular case, what must the prosecution prove beyond a reasonable doubt before we can say the defendant committed this crime?”

Only the issues instruction gives operational commands on whether to convict or acquit (e.g., “If you find… you should find the defendant guilty”).

C. “Unique Threat” Requirement

The “unique threat” language in section 12‑9(a‑5) applies when the threatened person is a sworn law enforcement officer:

The threat “must contain specific facts indicative of a unique threat to the person, family or property of the officer and not a generalized threat of harm.” (¶ 4)

In plain terms:

  • A vague, non‑specific outburst like “I hate cops” or “someone should hurt you someday” is more likely to be considered a “generalized threat of harm.”
  • A statement like “If I see you on the street, I will kill you and slash your throat” is a threat with “specific facts indicative of a unique threat” to that officer, because it:
    • targets a particular person (the named officer),
    • references a specific future circumstance (“if I see you on the street”), and
    • describes a specific act of violence (“slash your throat”).

The statute requires the latter type of specific, individualized threat for a conviction when the victim is an officer.

D. “Reasonable Apprehension”

“Reasonable apprehension of immediate or future bodily harm” means that the threat would cause a typical person in the officer’s position to reasonably fear being harmed, now or later. It does not require proof that the officer subjectively was frightened, but that the threat, viewed objectively, was serious and specific enough to cause such fear.

E. Plain Error

Plain error is a limited exception to the rule that a defendant must object to errors at trial to preserve them for appeal. Under Illinois law, a court may review unpreserved error only if:

  1. the evidence is so closely balanced that the error might have tipped the scales against the defendant; or
  2. the error is so serious that it affected the fairness of the trial and challenged the integrity of the judicial process.

But there is a threshold requirement: there must be an actual error. In Williams, the Court stopped at that threshold—finding no error in the instructions, and therefore no basis for plain‑error relief (¶ 23).

F. Overruling Precedent

When a higher court “overrules” a prior decision, it declares that the earlier decision was wrong on that legal point and will no longer be followed. The overruling can be:

  • Complete — ending the entire precedential value of the prior case; or
  • Partial — rejecting only a specific holding or rationale while leaving other parts intact.

Here, the Supreme Court partially overruled Warrington. It rejected Warrington’s holding that giving a definitional and issues instruction modeled on 11.49 and 11.50 was inherently inconsistent and constituted plain error, but did not disturb the separate holding that failing altogether to instruct the jury on the “unique threat” requirement was reversible (¶ 22 & n.1).

VIII. Conclusion

People v. Williams is a significant clarification of Illinois jury‑instruction law in prosecutions for threatening public officials—especially sworn law enforcement officers. The Court holds that:

  • IPI Criminal Nos. 11.49 (definitional) and 11.50 (issues) are not conflicting simply because only the latter includes the officer‑specific “unique threat” element.
  • When read together, these instructions “fully and fairly” convey the applicable law, and the jury could not convict without finding the “unique threat” requirement beyond a reasonable doubt.
  • People v. Warrington is overruled to the extent it held otherwise and treated such paired instructions as inherently inconsistent.
  • Because there was no instructional error, neither plain error nor ineffective assistance of counsel was present.

Doctrinally, the decision:

  • sharpens the line between definitional and mandatory (issues) instructions;
  • narrows the category of “conflicting instructions” that qualify as plain error to situations akin to Jenkins and Hartfield, where mandatory issues instructions give directly inconsistent commands on essential elements;
  • reaffirms that jurors are presumed to consider instructions as a whole and to follow the court’s directions not to disregard any instruction;
  • stabilizes the use of IPI 11.49 and 11.50 while preserving the substantive statutory safeguard that threats to officers must be uniquely targeted, not generalized.

In the broader landscape of Illinois criminal law, Williams will serve as a leading precedent on how to analyze alleged conflicts among pattern instructions, emphasizing structural context, the distinct roles of definitional and issues instructions, and the central requirement that error—real, not theoretical—must exist before appellate courts invoke the plain‑error doctrine to overturn jury verdicts.

Case Details

Year: 2025
Court: Supreme Court of Illinois

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