People v. Espinoza

(Court opinion corrected 10/2/14.) Indictments for domestic battery and endangering life and health of a child, alleging that Defendants struck a minor in the face, were defective as they contained no information identifying victim; State refused to amend indictments to include minor's initials. When challenging sufficiency of charging instrument before trial, a defendant is entitled to demand strict compliance with pleading requirements of Section 111-3 of Code of Criminal Procedure regardless of whether missing information at issue is available through other means. As charging instruments alleged crimes against individual victims, the identities of victims were essential allegations that must be included.(WRIGHT, concurring; O'BRIEN, dissenting.)