Illinois Appellate Court
Criminal Court
DUI
Defendant was convicted, after jury trial, of DUI and causing his vehicle tires to squeal. At trial, officer related incidental observation while he administered HGN test, that Defendant moved his head despite being instructed to keep it still. Such observation of failure to follow officer's instruction was properly admitted as independently relevant to issue of whether Defendant was impaired (JORGENSEN and BIRKETT, concurring.)