THE PEOPLE OF THE STATE OF ILLINOIS v. CHRISTIAN SHEPHERD (2026)

This case concerns whether a defendant charged with solicitation of murder for hire must have a partner who shares a genuine intent to commit first degree murder, or if it is enough that the defendant solicits another who has no intent of carrying out the murder. Christian Shepherd offered a fellow jail inmate, Robinson, money to kill the victim, complaining witness, and detectives in another case already against him; he also asked Robinson to kill an inmate he previously tried to hire to kill those people. A Will County jury convicted defendant of solicitation of murder for hire, and he appealed, arguing that he could not have procured another to commit first degree murder unless the other person actually agreed to commit the murder. Because Robinson reported defendant and cooperated with the investigation by wearing a wire and discussing arrangements with him on tape, defendant contended he never procured another.

The appellate court affirmed defendant's conviction, and so did the supreme court. Distinguishing conspiracy offenses from solicitation offenses, the court found that a unilateral agreement satisfies the procurement element of solicitation, where the offense specifically focuses on the defendant's state of mind and the defendant's act of commanding, encouraging, or requesting another to commit murder with the specific means of paying or promising to pay that person.

Justice O'Brien delivered the judgment of the court, with opinion.