People v. Geiler

Court dismissed Defendant's traffic citation based on violation of Supreme Court Rule 552, requiring arresting officer to transmit certain portions of citation to circuit court clerk within 48 hours after arrest. TIming requirement in Rule 552 is directory and thus dismissal of citation is not warranted unless noncompliance with the rule prejudices the defendants. A Rule 552 violation will not generally impede trial court in processing citations or prejudice a defendant's rights and thus it does not require exception to rule that procedural commands to governmental officials are directory. (THOMAS, KARMEIER, and THEIS, concurring; BURKE, GARMAN, and FREEMAN, specially concurring.)