Defendant was convicted, after jury trial, of obstructing justice by furnishing false information. Section 31-4(a)(1) of the Criminal Code includes a material impediment requirement. To prove a defendant guilty of the offense of obstructing justice, State must prove beyond a reasonable doubt that defendant knowingly furnished false information, defendant did so with the intent to prevent the apprehension of any person, and the false information must have materially impeded the administration of justice. Trial court erred in sustaining prosecutor’s objection and excluded any evidence relating to essential element of a material impediment, which prevented jury from being instructed on that issue. (A. BURKE, GARMAN, THEIS, and M. BURKE, concurring; KILBRIDE and KARMEIER, dissenting.)
Illinois Supreme Court
Criminal Court
Obstruction of Justice