The Illinois Supreme Court on Oct. 2, 2025, affirmed Matthew Smith’s conviction for first‑degree murder and reversed the Illinois Appellate Court’s order granting a new trial, ruling that excluding Smith’s mother from parts of his 2015 trial did not violate his constitutional right to a public trial and remanding for the appellate court to address other unresolved issues.

Justice O’Brien delivered the court’s opinion, concluding that the trial courtroom remained open to the public and that the trial court validly excluded a potential witness from the courtroom because she was listed as a possible witness. Justice O’Brien wrote that excluding Smith’s mother “did not implicate defendant’s public trial right.”

Why it matters: The court’s decision clarifies the distinction between the constitutional right to a public trial and the routine practice of excluding prospective witnesses from the courtroom. The opinion also resolves contested trial‑evidence issues that frequently arise in homicide prosecutions—lineup procedures, the admission and use of forensic gunshot‑residue analysis, the handling of a photograph found on the defendant, and portions of the prosecutor’s closing argument.

Facts and procedural posture
On Aug. 11, 2012, the victim, Kevin Guice, was shot outside the Press Box bar in Harvey, Illinois. The State charged Matthew Smith with first‑degree murder (720 ILCS 5/9‑1(a)(1) (West 2012)). Smith, who was 16 at the time of the offense, was tried by a jury; after conviction the trial court sentenced him to 30 years in prison. The Illinois Appellate Court, 2023 IL App (1st) 181070, reversed and ordered a new trial, finding a structural violation of Smith’s public‑trial right when the trial court excluded his mother; the State sought review and the Illinois Supreme Court granted leave.

Eyewitness and physical evidence
Four eyewitnesses identified Smith in pretrial lineups and in court testimony. Witnesses described the shooter as wearing a red and white shirt and, in some accounts, having a mohawk hairstyle. The police recovered a red and white shirt and a Smith & Wesson .357 revolver from a silver Buick after a vehicle pursuit; officers testified they apprehended a person who fled on foot from the vehicle and identified that person as Smith. Crime‑scene investigators recovered .380‑caliber shell casings at the Press Box; the .357 revolver recovered from the car could not be positively matched to all fragments recovered from the victim but could not be excluded as to at least one fragment.

Lineups and identification rulings
Smith argued that the second lineup was unduly suggestive because he was the only participant wearing a red and white shirt and because the fillers differed in age and hairstyle. The Supreme Court reversed the appellate court and held that the second lineup was not unduly suggestive. The court relied on precedent distinguishing a defendant’s wearing his own clothing from scenarios in which police spotlight a suspect (citing People v. Johnson and related cases) and concluded that discrepancies in age or hairstyle among fillers go to the weight of identification evidence, not necessarily admissibility.

Gunshot‑residue testimony and discovery
Mary Wong, a forensic scientist with the Illinois State Police (ISP), testified about primer gunshot‑residue testing. The ISP protocol she described requires three so‑called “tri‑component” particles to classify a sample as positive; she found a single tri‑component particle on Smith’s right hand and thus did not report a positive result under ISP standards. Wong also testified, over defense objection, that some outside laboratories use a one‑particle or four‑particle threshold. The appellate court concluded the State elicited testimony that conflicted with Wong’s pretrial report and labeled that a discovery violation. The Supreme Court agreed there was a discovery violation but held the error was not reversible given the overall strength of the evidence and because the record did not show prejudice sufficient to necessitate a new trial.

Photograph and jury access during deliberations
A photograph recovered with Smith’s property showed him wearing a red and white shirt and was admitted into evidence as property found on Smith at arrest. The trial court initially withheld the photograph from the jury but later, after the jury asked, “Photo taken inside bar?”, sent the photograph to the jury. The appellate court considered that act erroneous; the Supreme Court reversed that finding and held the trial court did not abuse its discretion in sending the admitted photograph to the jury, noting defense counsel had earlier described the photograph as taken “in the club” and effectively conceded its provenance at the pretrial motion hearing.

Closing argument
The appellate court flagged portions of the prosecutor’s rebuttal for comment, including statements that acquittal would require finding the State’s witnesses had “lied to your face.” The Supreme Court reviewed those remarks in context, found one isolated statement conceded by the State was improper but not reversible because the court’s instructions and the rest of the argument corrected the point, and found another challenged line did not present clear or obvious error.

Disposition and next steps
The Supreme Court reversed the appellate court’s judgment, affirmed the circuit court’s judgment of conviction and sentence, and remanded the cause to the appellate court to consider unresolved issues raised in the briefs but not addressed in the appellate court’s decision. The court’s opinion emphasizes limits on public‑trial claims where the courtroom remains open to other spectators and media and where exclusion is tied to the routine sequestration of potential witnesses.