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Missing Video Issues in Prosecution for DUI with Illinois State Police

  
  
  
  
  

Below is an outline for issues to consider in a Kladis motion during a DUI case.  Please contact me if you would like copies of the case law, ISP directives, or ISP training materials that were used to generate this list. 

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Kladis:

  • Officer testified that the in-car video system begins recording 5 seconds prior to the activation of the emergency lights.  At that time the microphone is also activated.
  • According to the Trooper, the video would have captured: images of defendant’s car 5 seconds prior to the stop; the manner in which the defendant pulled over and curbed her vehicle; defendant’s actions when he approached her vehicle; the manner in which defendant opened her car door and exited her vehicle; the defendant’s performance on SFST.
  • This Trooper turned off the emergency lights prior to transport to the station and it was then that the recording ended.
  • Court held both at SS and MTQ that “the video may not be used, or any testimony regarding what is on the video pertaining to just before the officer stopped the defendant and the time that the defendant was placed in the squad car, which would mean anything that happened on the street prior to her being placed in the squad car.”
  • State argued that Schmidt set out an exhaustive list, it did not.  Since Schmidt, 4 decades ago, video records made by in-squad cameras in misdemeanor DUI cases have become as relevant to the issue of proving or disproving guilt as the materials specifically mentioned in Schmidt.
  • 2009 General Assembly clarified and broadened the production and preservation safeguards for police recordings.  It established the general rule that when any law enforcement agency makes an in-squad video and audio recording in connection with either law enforcement or investigative duties, that recording shall be retained for a minimum period of 90 days.  720 ILCS 5/14-3(h-15).  Significantly, the legislature has also mandated and extended period of storage for certain recordings.  Where “the recordings *** are made as a part of an arrest or *** are deemed evidence in any criminal, civil, or administrative proceeding” they cannot be destroyed except “upon a final disposition and an order from the court.”
  • These legislative enactments express the clear legislative intent that the purpose of recording traffic stops and preserving these recordings for later production is to assist in the truth-seeking process by providing objective evidence of what occurred between law enforcement and the citizen.
  • Upon receiving the written Rule 237 notice to produce the video recording 5 days after defendant was arrested—and 25 days before it was destroyed—the State was placed on notice and should have taken appropriate steps to ensure that it was preserved.

ISP Directives:

  • V.B.3. Emergency equipment will be set to automatically activate the in-car video camera when the emergency lighting is activated.  In addition, officers will have the ability to activate the equipment manually.
  • V.B.4. The recording will not be interrupted or stopped until completion of the enforcement stop.  The enforcement stop is considered complete when the subject of the stop or officer has left the scene.  In case where the officer is transporting a subject, the stop is considered complete upon arrival at the destination.
  • V.B.8. Officers are encouraged to activate the camera any time it would be beneficial, such as observed suspicious activity, traffic problems, or crowd problems.
  • V.B.10. Officers will record activities inside the vehicle when transporting an arrestee or when an officer believes recording may assist with prosecution, enhance safety, or for any other lawful purpose.

Student Outline for In-Car Video Training (IL State Police Academy):

  • What the camera sees: the area in and around the violator’s vehicle, both while in motion and after the traffic stop.  Page 3
  • ICVS Record Activation immediately when observing impairment indicators and reasonable suspicion or probable cause does not yet exist, when violation observed, when decision to stop has been made. Page 7
  • Leave on audio/video until violator escorted into jail. Page 12

Instructor Outline for In-Car Video Training (IL State Police Academy):

  • Automatic ICVS activation policy (camera comes on when emergency lighting activated).  Page 5
  • Reasonable suspicion (articulate to the ICVS what you see).  Page 6
  • IVC violation (stop after you see the 1st violation…too many violation may work against you – Liability!!).  Page 7
  • Transport to jail (option-turn camera on violation i.e. impaired driver).  Page 8

Speed Cameras in Chicago

  
  
  
  
  

Governor Quinn signed legislation yesterday authorizing Mayor Emanuel to install cameras across nearly half of Chicago to catch speeding drivers and fine them as much as $100.  Both Quinn and Emanuel have touted this legislation as being about children’s safety, but the legislation speaks for itself and it has nothing to do with children’s safety and everything to do with generating income.

Under the law, cameras may be installed within one eighth of a mile of schools and parks, encompassing about 47% of the city of Chicago.   Speeders caught going 6-10 mph over the speed limit will be fined $50; 11 mph and above will be fined $100.  Similar to the red light camera tickets, the ticket will be mailed to the offender (whoever the car is registered to) and that person will have no real opportunity to challenge the ticket.

 

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The most glaring evidence that this has nothing to do with safety is that these tickets have no repercussions on a person’s driving record.  If you get caught speeding by the police, you’re guilty of a moving violation which is reflected on your driving record.  If you are caught speeding three times in a 12 month period, you’re license can be suspended by the Secretary of State.  Under the new legislation, there is no limit to the number of times someone can be caught speeding in a “safety zone” as long as he/she pays the tickets they accrue.  If this was really about children’s safety, wouldn’t there be stiffer penalties for higher speed in the “safety zone?”  Wouldn’t there be a penalty for repeatedly driving too fast in a “safety zone?”

It would be nice if our leaders realized what an insult it is to the public to try and disguise this legislation as a safety issue when it is so obviously just about generating revenue.

Winning a DUI motion then losing at trial--How?

  
  
  
  
  

People v. KZ

KZ was charged with an illegal left turn, negligent driving, violation of a solid red signal, driving with no insurance, failure to keep in lanes and DUI (a2).  Our firm prevailed in lifting his DUI suspension and also prevailed at a motion to quash.  At the motion to quash the judge found that there was not enough evidence to support a finding of probable cause when KZ was transported back to the station so that all of the evidence (mainly Standardized Field Sobriety Tests) at the station was suppressed at trial.  Generally, this is the fatal blow to the State's case and they dismiss the charges at that point.  In this case, the State indicated it would still be proceeding on the charges so our firm filed a demand for speedy trial.  On the final day that the State was able to proceed they answered ready and we went to trial.  Bear in mind, this trial was going to include even less evidence than what was presented at the motion to quash.  But here's the problem: at the Daley Center, the judges change each day so this judge had no idea what the other judge heard at the motion to quash.  Prior to the trial beginning we made sure to point out that the motion had been granted and have the judge review the prior judge's ruling so that it was clear that the State could put on no evidence after the point in time that KZ was placed in the squad car.  The judge herself pointed out to the State, pre-trial, that it would seem impossible for her to find a Defendant guilty beyond a reasonable doubt when a prior judge had made a ruling that there wasn't even enough evidence to form probable cause for the arrest.  But I digress...

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We proceeded to trial on all of the counts and the judge made the follwoing ruling: (1) illegal left turn--not guilty; (2) negligent driving--not guilty; (3) violation of a solid red signal--not guilty; (4) failure to keep in lanes--guilty; (5) no insurance--guilty; (6) driving under the influence (a2)--GUILTY.

Needless to say we have a motion to reconsider pending with the following arguments:

(1) The State failed to prove the Defendant guilty of driving under the influence beyond a reasonable doubt.  The judge based her ruling on a strong odor of alcoholic beverage, a loud voice, shifting weight, and the Defendant being uncooperative.

(2) Because the Court previously found that the same evidence was not enough for probable cause, it could not now find that the same evidence rose to the level of beyond a reasonable doubt.  This is a situation that would not occur at any other courthouse.  I think that the judge believed that the State's case at trial included another witness who was not present at the motion to quash, but it didn't.  The State put on the exact same testimony, knowing the court had found no probable cause in the hopes that it could convince a judge that this was something new and different and rose to the level of guilt beyond a reasonable doubt.

(3) The court's ruling was logically inconsistent.  If the court found the Defendant not guilty on minor movers where the burden is a preponderance of the evidence, they cannot then find a Defendant guilty of a charge based on the same officer's testimony that requires proof beyond a reasonable doubt.  You either believe the officers or you don't for all of the charges.


"Where were the keys, Officer?" Actual Physical Control & DUI

  
  
  
  
  
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People v. ZT
ZT was charged with DUI, Leaving the Scene of an Accident, Failure to carry a License, and Driving with no insurance.  At a bench trial, the state called the arresting officer as its only witness and also introduced a video of the Standardized Field Sobriety Tests and some conversations between the Defendant and the arresting officer.  Defendant's motion for directed finding was granted at the close of the State's case due to a lack of evidence regarding actual physical control of the vehicle.
The arresting officer was called to the scene of a three car accident.  She speaks to a number of people on the scene and approximately 10-15 minutes later, Defendant arrives on the scene on foot and spontaneously states, "I'm the driver of that car, I hit the other cars."  No complaining witness is ever called to the stand and later, on the video, Defendant is heard repeatedly telling the officer that a female was driving his vehicle and left the scene of the accident.  On cross examination, defense counsel questioned the officer about the keys to Defendant's vehicle.  Although the keys were mentioned no where in her reports, she suddenly remembers (2 years later) that the defendant had the keys to the vehicle in his sock when he was arrested.  Surprisingly, once the video is used in the arrest, the offender never again states that he was the driver and continues to allege that a female was driving his vehicle and fled the scene of the accident.
All in all, the witness was not enough for the state to put on their case and the motion for directed finding was granted on all counts.

Sarah Manning nominated to Illinois Rising Stars 2012!

  
  
  
  
  

Check out her Profile!

Super Lawyers Selection Process

Super Lawyers Selection Process Blessed by Courts and Bar Associations Across the Country

Bar associations and courts across the country have recognized the legitimacy of the Super Lawyers selection process. Most recently, the New Jersey Supreme Court upheld the findings of a Special Master assigned by the court to, among other things, examine the details of our process. In his July 2008 report, the Special Master lauded our lawyer-rating process, stating:

“[The Super Lawyers selection process] is a comprehensive, good-faith and detailed attempt to produce a list of lawyers that have attained high peer recognition, meet ethical standards, and have demonstrated some degree of achievement in their field."

"Suffice to say, the selection procedures employed by [Super Lawyers] are very sophisticated, comprehensive and complex."

“It is absolutely clear from this record that [Super Lawyers does] not permit a lawyer to buy one’s way onto the list, nor is there any requirement for the purchase of any product for inclusion in the lists or any quid pro quo of any kind or nature associated with the evaluation and listing of an attorney or in the subsequent advertising of one’s inclusion in the lists.” 

Overview

Super Lawyers selects attorneys using a rigorous, multiphase rating process. Peer nominations and evaluations are combined with third party research. Each candidate is evaluated on 12 indicators of peer recognition and professional achievement. Selections are made on an annual, state-by-state basis. 

The objective is to create a credible, comprehensive and diverse listing of outstanding attorneys that can be used as a resource for attorneys and consumers searching for legal counsel. Since Super Lawyers is intended to be used as an aid in selecting a lawyer, we limit the lawyer ratings to those who can be hired and retained by the public, i.e., lawyers in private practice and Legal Aid attorneys.

The Super Lawyers selection process involves three basic steps: creation of the candidate pool; evaluation of candidates by the research department; and peer evaluation by practice area.

Step One: Creation of the Candidate Pool

Lawyers enter the candidate pool by being formally nominated by a peer or if identified by the research department during the research process.

Formal nominations

Once a year, we invite lawyers in each state to nominate the top attorneys they've personally observed in action. Lawyers may nominate attorneys in their own firm, but these nominations count only if each in-firm nomination is matched by at least one out-firm nomination.

Each nomination carries a point value. An out-firm nomination has substantially greater point value than an in-firm nomination. Lawyers cannot nominate themselves, and must limit their nominations to others who practice in the same state.

Our procedures and database have several safeguards that prevent lawyers from "gaming" the system. For example, we track who nominates whom. This helps us detect any excessive "back-scratch" nominations (lawyers nominating each other) and "block nominations" (where members of the same law firm all cast identical nominations). We also prohibit lawyers from engaging in "campaigning" or solicitation of nominations from other lawyers.

While important, the nomination phase is simply the first step in our process. It puts lawyers on our radar for further research and evaluation, and awards points in our rating system. But we limit the value of those points so that no matter how many nominations one receives, it will not guarantee selection.  

Our attorney-led research staff searches for lawyers who have attained certain honors, results or credentials, which indicate a high degree of peer recognition or professional competence. For example, certification as a specialist in a particular area of practice, or admission to prestigious colleges or academies, e.g., The American College of Trial Lawyers. The staff identifies these credentials by reviewing a proprietary list of database and online sources, including national and local legal trade publications.  

Most of the lawyers we identify in this process have also been nominated by their peers. Occasionally, however, we find outstanding lawyers who have been overlooked in the nomination process. These may include: lawyers with national litigation practices who rarely appear in the courts of their home jurisdiction; lawyers in smaller firms or from smaller communities; and lawyers practicing in less visible or highly specialized practice areas.

Informal nominations

Throughout the year, readers, clients and attorneys who are not eligible to formally nominate (that is, actively licensed to practice in the same state as the nominee) send us names of lawyers we should consider for inclusion. Though no points are awarded, we add these lawyers to the candidate pool for further research and evaluation.

Step Two: Evaluation of Lawyers in Candidate Pool

Our research department evaluates each candidate based on these 12 indicators of peer recognition and professional achievement: verdicts and settlements; transactions; representative clients; experience; honors and awards; special licenses and certifications; position within law firm; bar and or other professional activity; pro bono and community service as a lawyer; scholarly lectures and writings; education and employment background; and other outstanding achievements.

These indicators are not treated equally; some have a higher maximum point value than others.  

Step Three: Peer Evaluation by Practice Area

In this step, also known as the "blue ribbon review," candidates are grouped according to their primary areas of practice. The candidates in each practice area with the highest point totals from steps one and two above are asked to serve on a blue ribbon panel. The panelists are then provided a list of candidates from their practice areas to review, rating them on a scale of one to ten.

Final Selection

Candidates are grouped into four firm-size categories. Those with the highest point totals from each category are selected. This means solo and small firm lawyers are compared with other solo and small firm attorneys, and large firm lawyers compete with other large firm lawyers.  Five percent of the total lawyers in the state are selected for inclusion in Super Lawyers.

Before Publishing

The research staff checks each candidate's standing with the local licensing authority. Each candidate is asked to aver that they have never been subject to disciplinary or criminal proceedings.

Final Internet searches are performed on each candidate to ensure there are no outstanding matters that would reflect adversely on the lawyer. We also contact each lawyer to ensure accuracy of all published information.

Publication

The final published list represents no more than 5 percent of the lawyers in the state. The lists are published annually in state and regional editions of Super Lawyers magazines and in inserts and special advertising sections in leading city and regional magazines and newspapers. All attorneys selected for inclusion in Super Lawyers, regardless of year, can be found on superlawyers.com.

 

The Rising Stars selection process

The selection process for Rising Stars is the same as the Super Lawyers selection process except that: 1) to be eligible for inclusion in Rising Stars, a candidate must be either 40 years old or younger or in practice for ten years or less; 2) Candidates for Rising Stars do not go through step three above—peer evaluation by practice area. While up to five percent of the lawyers in the state are named to Super Lawyers, no more than 2.5 percent are named to the Rising Stars list.

Analysis of Drug DUI

  
  
  
  
  
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ANALYSIS OF 625 ILCS 5/11-501 (a) (6)

The language of 625 ILCS 5/11-501 is clear and unambiguous.

            The statute is divided into six different sections each relating to a different offense of driving under the influence.  The language of 11-501 (a) (1) requires a breath test to quantify the amount of alcohol “in the person’s blood or breath.”  Unlike sections (a) (2), (a) (3), (a) (4) and (a) (5), the final section of the statute, (a) (6), also uses the language “in the person’s breath, blood, or urine.”  While findings of guilt under sections (a) (2) through (a) (5) may be based on an officer’s opinion that the defendant is under the influence, a finding of guilt under section (a) (6) requires chemical testing.  “When determining legislative intent, a court will construe the language of the statute according to its plain and ordinary meaning and if the statutory language is clear and unambiguous, the statute’s plain meaning will be given effect.”  Ramos v City of Peru, 333 Ill. App. 3d 75, 77-78 (2002).  Because the legislature used the word “in” only in sections (a) (1) and (a) (6) we must give that word effect in both sections.  To determine whether a substance is “in” a person’s blood, breath, or urine chemical testing is required.

People v. Allen is the controlling case for analysis of 11-501 (a) (6).

            Recently at The Daley Center, decisions in (a) (6) cases have been based on People v. Briseno, 343 Ill. App 3d 953 (2003), because Briseno is a 1st District case.  The controlling case for analysis of 11-501 (a) (6) is People v. Allen, 375 Ill. App. 3d 810 (2007).  Reliance on Briseno is incorrect for the following reasons.

There is one appellate court in the State of Illinois.  Article VI, Section 1 of the Illinois Constitution states, “The judicial power is vested in a Supreme Court, an Appellate Court and Circuit Courts.”  The appellate court is divided into branches, but those branches do not change the fact that the court is a single, unitary authority, whose decisions bind all lower circuit courts.  705 ILCS 25/1 (2009)People v. Allen is a more recent analysis of the (a) (6) statute which deals with the language of the statute itself.  “The primary rule of statutory construction is to ascertain and give effect to the intention of the legislature, and that inquiry appropriately begins with the language of the statute.”  People v. Hare 119 Ill. 2d. 441, 447 (1988).  In Allen, the court pointed out that the only witness called by the State clearly stated that it was impossible to tell whether defendant had zero milligrams or 100 milligrams of cannabis in his breathe or blood based on an odor of cannabis.  Allen at 816.  The court in Allen interpreted the language of the statute, in particular the use of the word “in,” to hold that without chemical testing, there is no way to determine whether there is any amount of a drug in a person’s system for purposes of a DUI conviction under 11-501 (a) (6).

People v. Briseno does not use the correct framework for an analysis of a conviction under 11-501 (a) (6).

The court in Briseno listed the following as factors for a finding of guilt under 11-501 (a) (6):

(1)   operation of a motor vehicle,

(2)   odor of cannabis in vehicle,

(3)   odor of cannabis on defendant’s breath,

(4)   admission by defendant to smoking cannabis,

(5)   slurred speech,

(6)   dilated pupils,

(7)   defendant’s motor skills being slower than average, and

(8)   poor performance on standardized field sobriety tests.  Briseno at 960.

First of all, the odor of cannabis within a vehicle does not prove that the driver has cannabis “in” his/her system.  According to statute:

  “Cannabis includes marihuana, hashish and other substances which are identified as including any part of the plant Cannabis Sativa, whether growing or not; the seeds thereof, the resin extracted from any part of such plant; and any compound, manufacture, salt, derivative, mixture, or preparation of such plan, its seeds, or resin, including tetrahydrocannabinol (THC) and all other cannabinol derivatives, including its naturally occurring or synthetically produced ingredients, whether produced directly or indirectly by extraction, or independently by means of chemical synthesis or by a combination of extraction and chemical synthesis; but shall not include the mature stalks of such plant, fiber produced from such stalks, oil or cake made from the seeds of such plant, any other compound, manufacture, salt, derivative, mixture, or preparation of such mature stalks (except the resin extracted therefrom), fiber, oil or cake, or the sterilized seed of such plant which is incapable of germination.  720 ILCS 550/3(a) (2009).

Unlike other controlled substances, cannabis is unique in that certain varieties or forms of the plant are perfectly legal.  This distinction is of critical importance in a DUI prosecution.  Without either recovery of the illicit substance itself, or a blood or urine test establishing consumption of the illicit substance, there is no tangible proof of the type or variety of cannabis.  Because the law criminalizes certain forms or varieties of the plant and not others, the smell of the plant alone cannot establish a violation of 11-501 (a) (6).  If the court is not inclined to require chemical testing to prove guilt on an (a) (6) charge, then the expertise of the officer in cannabis detection becomes of critical importance.

  Secondly, the odor of cannabis “on” a person’s breath means nothing.  The statute requires that a person have an amount of drug in their blood, breath, or urine.  “The statute does not criminalize having breathe that smells like burnt cannabis.”  Allen at 816.

The third factor relied on in Briseno was an admission of smoking cannabis by the defendant.  People v. Park is instructive here.

Park’s own alleged admission was insufficient to convict him of the offense charged.  Even assuming that Park’s alleged statement was admissible, its probative value or weight is limited, in the absence of substantial evidence that…defendant had some means of knowing that the substance in question contained cannabis.  …the well established rule governing this situation is that requiring substantial, independent corroboration of the defendant’s alleged admission of the element of the corpus delicti.  The reasons for this ancient rule are many, but underlying them all is the general problem of the trustworthiness of such alleged admissions.  People v. Park 72 Ill 2d 203, 212 (1978).

In Park the court reaffirmed that an admission alone is not enough to affirm a conviction.  There must be some other substantial, independent corroborating evidence (e.g. lab testing of substance recovered or, in (a) (6) cases, chemical testing of defendant) that the substance in question was actually cannabis.

The last four factors cited by the Briseno court are all observations made of the defendant by the arresting officer.  The court in Briseno mistakenly undertook an analysis of the officer’s observations and whether or not he/she was able to form an opinion about whether the defendant was under the influence based on those observations.  A finding of guilt under 11-501 (a) (6) cannot be based on opinion evidence.  Because the language of 11-501 (a) (6) is analogous to 11-501 (a) (1), a court cannot make a finding of guilt under 11-501 (a) (6) without chemical testing.

The Briseno court mistakenly analyzes an (a) (6) case using the framework set up by cases analyzing findings of guilt under 11-501 (a) (5).  In People v. Jacquith, 129 Ill App. 3d 107, the First District Appellate Court noted a distinction between the competence of a police witness to testify to alcohol intoxication versus drug intoxication.  While any lay witness could testify to the effect of alcohol intoxication, the court held that an officer must have some level of professional experience with drugs before his testimony on the subject can support a finding of driving under the influence of drugs.  Specifically, the court found that an officer “who claimed no experience with drug arrests, testify(ing) that he believed, based on defendant’s behavior and appearance, that the defendant was under the influence of alcohol and “some other influence,” was “not the level of expertise that has been held necessary in those jurisdictions which have addressed the issue of competent evidence to sustain a conviction for driving under the influence of drugs.”  Jacquith at 112-113.  In the subsequent decision of People v. Bitterman, 142 Ill. App. 3d 1062, 1064-1065, the First District clarified the holding of Jacquith, explaining that “the officer had to be qualified by the court as an expert in order to reach the conclusion that an accused was under the influence of drugs.”  So even if the court uses Briseno’s incorrect analysis of an (a) (6) case, the court would still have to find that the officer was an expert in drug detection before his/her testimony regarding an opinion of drug intoxication may be admissible.

Conclusion

Interpreting the language of the DUI statute, chemical testing is required to sustain a finding of guilt on a charge under 11-501 (a) (6).

 

 

Witnesses and Tactics for a DUI Summary Suspension Hearing

  
  
  
  
  

  

People v JD

JD is involved in a car accident as a passenger.  She remembers nothing and when she awakes at the hospital, she is given DUI citations and placed under arrest.  She hires our office and insists that she was not driving.  A male "friend" of hers was the driver but refuses to come into court to testify.  She is a second offender so she has a three year suspension of her driving privileges and, if found guilty, her license will be revoked.  This is a must win case.  In looking through the discovery, it seems no one can identify her as the driver.  The ambulance and fire personnel never see her in the driver's seat, nor does the Trooper who arrives on scene later.  The problem is that she supposedly admits to all of these witnesses that she was driving.  She has no recollection of anything at the scene.  So, we have to try and get the driver to come in and testify that he was driving, not her.  If nothing else, we need information from him about what was happening at the scene: who arrived first, where was the defendant, where was he, what statements were made, etc.  It's still unclear whether he will cooperate.  We could use a subpoena to get him in, but what if that aggravates him and then he won't give us the information we need?

In analyzing her petition to rescind the statutory summary suspension, how can we lay out our prima facie case?  She remembers nothing.  The witness won't come in.  The trooper is most likely not going to give us what we need to call the arrest into question.  So, what next?

We're continuing to try and work with the actual driver to have him testify.  In the meantime, we are going to set the case for trial first.  If we can get a judge to rule that the defendant was not the driver, we can win the statutory summary suspension based on case law.

It's not going to be easy but we will fight for our client because it's the right thing to do.

DUI Reality Show debuts on TLC TONIGHT!

  
  
  
  
  
If this show raises awareness about drinking and/or drug use and driving, it is a good thing.  I'll reserve judgment until I view the full show.

Press Release 11/28/11 Radio Interview, Roadside Safety Checks

  
  
  
  
  

Click here for more information about Sarah Manning's upcoming interview on

 

Listen to internet radio with Law and Money Talk Radio on Blog Talk Radio

Driving on Revoked License-Lost Motion to Quash but "Won" Case

  
  
  
  
  

 

 

seatbelt resized 600People v. AA

AA was charged with driving on a revoked license.  It was his fourth offense since his license was revoked for a DUI in 1999.  He was eligible for a felony upgrade and the state offered 180 days in Cook County Department of Corrections.  AA had no other background.  His girlfriend of 6 years was diagnosed with breast cancer shortly after he was arrested for this case.  While the case was pending, he was coordinating her cancer care (chemotherapy, surgery, radiation, etc.), working full time as a nurse's assistant, and helping raise her three children.  Bottom line, he could not do jail time and needed to figure out a way to either win the case or avoid jail somehow.  Because the only two tickets issued were a seatbelt ticket and the driving on revoked and AA claimed he was wearing his seatbelt, we decided to run a motion to quash the stop.  In cases like this, where the officer does not prepare an arrest report, it's hard to gauge how the hearing will go as the tickets are the only discovery available.  We ran the motion and lost.  We immediately proceeded to a conference with the judge to try and agree on a sentence.  We tendered a letter from Illinois Cancer Centers detailing the level of care AA was providing to his girlfriend as well as a letter from her oldest daughter detailing his involvement in their family.  We also argued that because the state opted not to upgrade this case to a felony, the mandatory minimums did not apply and the judge was free to use his discretion in sentencing.  He did so and gave AA the option of a 14 day sentence in jail (he would serve 7 days) or 18 months to complete 400 hours of monitored community service.  AA could not be happier and we are looking forward to working with him soon to reinstate his license at the Secretary of State.  Cases like this, where I can find a way to help people who really need it and make a real difference in their lives are why I became a lawyer.

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