Illinois Appellate Court
Criminal Court
resisting arrest
Defendant was convicted, after jury trial, of resisting a police officer and attempting to obstruct justice. Video of arrest, and testimony of officer, showed that Defendant repeatedly resisted officers' requests that she place her hands behind her back, and Defendant did not submit until five officers restrained her, including using Taser gun, placing knee to her back, and using pressure points. Court erred in failing to address all of the Rule 431(b) principles with the alternate juror who was later empannelled when another juror was dismissed. However, no plain error, as evidence was not closely balanced. (CUNNINGHAM and HOFFMAN, concurring.)