Quick Take on Illinois Supreme Court Opinion Issued Wednesday, October 28, 2020
The Illinois Supreme Court handed down one opinion on Wednesday, October 28. In People v. Casler, the Supreme Court reversed and remanded a defendant’s conviction for obstructing justice when he provided a false name to police.
By Kerry J. Bryson, Office of the State Appellate Defender
Two Carbondale police officers were on foot patrol of a local hotel when they saw Rasheed Casler open a hotel room door, step out into the hallway, and then immediately retreat back into the hotel room when Casler saw the officers. One of the officers recognized Casler, not by name, but as someone he had dealt with previously. The officers smelled the odor of burnt cannabis emanating from the hotel room and knocked on the door. A woman answered, and the officers observed two men and two women in the room, but not Casler.
The officers noticed that the bathroom door was closed, knocked, and asked if anyone was inside. Casler responded that he was using the bathroom and identified himself as Jakuta King Williams but said he did not have identification on him. A check of that name did not reveal any records. When Casler exited the bathroom, one of the officers recognized him and remembered his name from a prior arrest. When Casler’s name was run, an outstanding warrant was discovered, and Casler was arrested.
Casler was convicted of obstructing justice by furnishing false information. On appeal, he challenged that conviction on the basis that his conduct did not materially interfere with a police investigation because his true identity was readily discovered and he was promptly arrested on the outstanding warrant. The appellate court rejected that argument and affirmed Casler’s conviction. Today, the Illinois Supreme Court reversed, with two justices dissenting.
The Court first looked to the relevant criminal statute, 720 ILCS 5/31-4(a)(1), which provides that a person obstructs justice when, with intent to prevent the apprehension or obstruct the prosecution or defense of any person, he or she knowingly furnishes false information (among other conduct). Examining the plain language of the statute, the Court concluded that the provision of false information must constitute a material impediment to the administration of justice in order to establish obstruction of justice. The Court also looked at several prior obstruction cases where a material impediment requirement was held to apply. No material impediment was shown at Casler’s trial.
The Court went on to consider the appropriate remedy here, where the trial proceeded as though material impediment was not an element of the offense. The Court found that at trial, the judge excluded any evidence relating to the question of material impediment when it sustained a state objection to defense counsel’s questions tending to suggest that the officers were not impeded in their official functions by Casler’s giving them a false name. Further, both the charge and jury instructions did not include “material impediment” as an element of the offense. So, the Court concluded that the jury never considered the question of whether defendant’s furnishing a false name materially impeded the administration of justice. Under the instructions that were given, the evidence was sufficient to find each of the elements proved beyond a reasonable doubt.
Ultimately, the Court concluded that the error was “more akin to trial error than to sufficiency of the evidence.” Because the state had no reason to offer evidence of material impediment where the Supreme Court had not yet held that to be an essential element of the offense, the Court found it appropriate to reverse and remand for a new trial rather than to reverse outright.
Justices Kilbride and Karmeier both authored dissents explaining their views that the statute does not contain a material impediment element. Both would have affirmed Casler’s conviction here. Justice Karmeier went on to explain, however, that if such a requirement exists, the state simply failed to meet its burden and defendant’s conviction should be reversed outright.