Illinois Appellate Court
Criminal Court
Indictment
State filed charges of unlawful possession of a hypodermic needle 18 months after incidents. Defendant must show actual and substantial prejudice as a result of preindictment delay. Assertions as to possibility of prejudice, or personal inconvenience, are insufficient grounds for dismissal due to unreasonable preindictment delay. (KNECHT and TURNER, concurring.)