Illinois Appellate Court
Criminal Court
Sufficiency of Evidence
Defendant appealed his conviction for resisting or obstructing a police officer, arguing that the evidence was not sufficient to prove him guilty beyond a reasonable doubt and that the trial court did not conduct an adequate Batson hearing. The appellate court reversed, finding that the defendant’s brief refusal to place his foot inside the officer’s squad car did not materially impede the officer in the performance of his duties and did not threaten his safety or delay transport by an appreciable period of time. (TURNER and CAVANAGH, concurring)