People v. Nielsen

Defendant pled guilty to reckless driving at a hearing pursuant to a traffic ticket and subsequently moved to dismiss separate felony charges for attempted murder and aggravated battery that the State brought based on facts arising from the same incident as the traffic ticket. The trial court denied defendant’s motion and he filed an interlocutory appeal, arguing that the compulsory joinder statute barred the State from pursuing felony charges. The appellate court affirmed the circuit court’s decision and denied defendant’s petition for rehearing, explaining that the Illinois supreme court has held that the compulsory joinder statute does not apply to scenarios like this one where the offenses were separately charged by the use of a uniform citation and complaint form provided for traffic offenses. (MITCHELL and LYLE, concurring)