People v. Strobel

Illinois Appellate Court
Criminal Court
Citation
Case Number: 
2014 IL App (1st) 130300
Decision Date: 
June 30, 2014
District: 
1st Dist.
Division/County: 
Cook Co., 2d Div.
Justice: 
PIERCE
Holding: 
Reversed and remanded.
Court's discovery sanction barred State from presenting any testimony or video at trial as to DUI field sobriety tests due to lack of contemporaneous audio recording. Sanction was too harsh, as no evidence in record to support inference or suggestion that police or prosecution intentionally or inadvertently destroyed any preexisting discoverable evidence. (HARRIS and LIU, concurring.)