Illinois Appellate Court
Criminal Court
Due Process
(Court opinion corrected 5/8/13.) Defendant was convicted of three counts of felony disorderly conduct, from making a false report to public employees. Structural error occurred when court allowed State to exercise peremptory challenge to excuse a juror in middle of trial, in denial of due process. Court improperly allowed State to invade an impartial jury, as sanction for Defendant violating order in limine barring reference to police shooting which had occurred in the church where Defendant's parents were pastors. (BURKE and HUDSON, concurring.)