Authored By: Tala Bafawi
Case Name: The People of the State of Illinois v. Rustin C. Sabich
Court: Circuit Court of Cook County – Criminal Division
Date of Decision: 11 March 2024
Citation: 2024 ILCC Crim. 402
Introduction
This case summary analyzes The People of the State of Illinois v. Rustin C. Sabich, a highly publicised criminal trial involving the charge of first-degree murder against a sitting prosecutor. The plaintiff, the People of the State of Illinois, was represented by Special Prosecutor Nico Della Guardia. The defendant, Rustin C. Sabich, served as the Chief Deputy Prosecutor of Cook County and stood accused of murdering Assistant Prosecutor Carolyn Polhemus, with whom he had a prior extramarital affair.
Following the discovery of Polhemus’s body, the State’s Attorney’s Office initiated an internal inquiry. Sabich, once a lead investigator in the case, was implicated based on forensic findings and personal history with the deceased. As evidence suggesting his involvement emerged, he was placed on administrative leave, later indicted, and stood trial before a jury. The case attracted widespread media attention, not only for its legal complexity but also for the personal and political entanglements embedded within the prosecutorial office.
Facts of the Case
Carolyn Polhemus was found dead in her home, having suffered blunt force trauma. Indications of sexual assault were also noted at the scene. What caught the court’s attention?? was that Carolyn was killed in the same manner as a past criminal they had prosecuted. Back then, Carolyn and Rustin were in charge of that case, and they were the only two who knew the specific details of how the crime was committed. The court had found the murderer guilty. Rustin Sabich, a senior figure in the same prosecutor’s office, had recently ended a clandestine affair with the victim. Forensic analysis identified his fingerprints and biological material in the victim’s home, and electronic records placed him in the vicinity during the estimated time of death. These facts raised concerns about Rustin and placed him in a position where he had to defend himself.
Sabich did not initially disclose the extent of his prior relationship with Polhemus, a fact that cast suspicion on his intent and integrity. The circumstantial evidence, coupled with behavioral
inconsistencies, became central to the prosecution’s narrative. The defendant’s former role as an investigator in the case raised questions regarding potential manipulation of internal procedures, amplifying concerns about conflict of interest and prosecutorial ethics.
Legal Issues
The primary legal issue: was whether the prosecution met its burden of proving, beyond a reasonable doubt, that Rustin Sabich intentionally and unlawfully caused Carolyn Polhemus’s death, thereby satisfying the statutory elements of first-degree murder under Illinois Criminal Code § 9-1(a).
Secondary legal issues included:
- The admissibility and sufficiency of circumstantial forensic evidence;
- The integrity of the investigation and whether prosecutorial misconduct or political rivalry compromised the process;
- Whether the defendant’s constitutional right to a fair trial under the Sixth Amendment was upheld;
- The propriety of jury instructions, particularly concerning motive and the introduction of prior bad acts under Illinois Rules of Evidence §§ 403 and 404(b).
Arguments Presented
Prosecution’s Argument
The prosecution contended that Sabich had both motive and opportunity to commit the crime. The motive was rooted in jealousy and fear of public exposure of the affair, potentially jeopardizing his career and marriage. Forensic evidence, including DNA and fingerprints, placed him at the scene. Additionally, Sabich’s failure to disclose his relationship and his inconsistent cooperation with investigators were interpreted as signs of consciousness of guilt. Prosecutor Della Guardia further argued that Sabich’s influential position enabled him to interfere with the early phases of the investigation, manipulating the process in subtle but impactful ways.
Defence’s Argument
The defence countered that the forensic evidence was entirely consistent with prior consensual contact, not violence or homicide. He supported his defense by the fact that he actually loved Carolyn and there is no way to kill her or commit this cruel crime against her. There was no direct evidence placing Sabich at the scene at the time of the murder, nor any witnesses linking him to the act. The defence also argued that the case was politically motivated. Prosecutor Della Guardia, a known rival, allegedly exploited the case for personal gain. Furthermore, Sabich’s defence pointed to violations of his rights stemming from pre-trial publicity and biased investigative practices. The overall prosecutorial conduct was framed as overzealous and ethically questionable.
Court’s Analysis
The court placed significant emphasis on the legal standard of beyond a reasonable doubt, reiterating its centrality in criminal law. The trial judge was particularly cautious in guiding the jury on the use of circumstantial evidence, stressing that motive cannot replace substantive proof of criminal conduct.
In reviewing the prosecution’s case, the court found the forensic evidence—while notable—did not conclusively establish that Sabich committed the murder. DNA and fingerprint evidence confirmed his prior presence at the residence but failed to prove involvement in the fatal incident. The timeline was vague, and gaps in the chain of custody of evidence weakened its probative value.
Regarding admissibility of character evidence, the court applied Illinois Rules of Evidence §§ 403 and 404(b), excluding certain prior bad acts due to their prejudicial impact outweighing their relevance. Additionally, concerns about pre-trial media coverage and its potential to bias jurors were acknowledged, though the court found no definitive proof of actual prejudice during voir dire.
Key constitutional safeguards were reviewed. Under Brady v. Maryland [373 US 83 (1963)], the court examined whether exculpatory evidence was withheld. No such violation was established, though the court criticized the prosecution’s narrow disclosures. Sabich’s Sixth Amendment rights were deemed intact, though tested by the case’s publicity and internal politics.
Ultimately, the court found that the defence had successfully raised reasonable doubt by impeaching prosecution witnesses and pointing out evidentiary inconsistencies. The verdict depended on the insufficiency of direct evidence and the jury’s reluctance to convict based solely on motive and circumstance.
Decision
The jury returned a unanimous verdict of not guilty on the charge of first-degree murder. Sabich was acquitted and immediately released from custody. Given the weaknesses in the prosecution’s case exposed during trial, the State declined to pursue lesser charges or reopen the investigation.
Public Commentary
The trial prompted widespread discussion in legal circles and media outlets. Analysts questioned the ethics of Special Prosecutor Della Guardia’s involvement, with some alleging political motivations drove the prosecution. Although the verdict resolved Sabich’s legal liability, the case left lingering doubts about internal dynamics within the Cook County Prosecutor’s Office.
Significance
This case serves as a cautionary example of the risks associated with prosecutorial overreach and the use of circumstantial evidence in criminal trials. While not precedent-setting, its impact on legal practice was notable, particularly regarding internal investigations involving high-ranking legal professionals.
Following the trial, reforms were reportedly implemented within the State’s Attorney’s Office. These included updated recusal guidelines and conflict-of-interest protocols to prevent future ethical lapses. Allegations against Della Guardia triggered a review by the Illinois Bar’s ethics committee, though no formal sanctions were issued.
The case underscored the judiciary’s role in safeguarding constitutional rights, particularly when the accused is a public figure vulnerable to political manipulation. It also reaffirmed that motive—while relevant—cannot supplant the need for tangible, corroborated proof in securing a conviction.
Conclusion
The acquittal of Rustin C. Sabich in The People v. Sabich reiterates the fundamental principles of the American criminal justice system. It highlights the judiciary’s duty to enforce the presumption of innocence and maintain high evidentiary standards, even in emotionally charged or politically fraught cases.
From a legal analysis standpoint, the case exemplifies the importance of procedural fairness and the perils of allowing personal or political agendas to influence prosecutorial decisions. While Sabich’s moral conduct may be questionable, the court’s role is not to enforce morality but to apply the law. In doing so, it preserved the integrity of the legal process by refusing to convict an individual without sufficient proof.
Reference(S):
- Presumed Innocent (Apple TV+, 2024), created by David E. Kelley • Scott Turow, Presumed Innocent (Farrar, Straus and Giroux, 1987) • Illinois Criminal Code § 9-1(a)
- Illinois Rules of Evidence §§ 403, 404(b)
- Brady v. Maryland, 373 US 83 (1963)
- Sixth Amendment to the United States Constitution
