Illinois Supreme Court
Criminal Court
Evidence
Hearsay
The Illinois Supreme Court resolved a conflict between section 11-501.4(a) of the Illinois Vehicle Code and Illinois Rule of Evidence 803(6) by striking the provision in IRE 803(6) excluding medical records in criminal cases from the business exception to the hearsay rule, saying that the exclusion was “not logically defensible.” Applying the amended Rule 803(6) to the appeal and noting that changes to evidentiary rules do not create ex post facto concerns, the court held that the circuit court did not err in admitting chemical blood tests taken while defendant was in the hospital. (GARMAN, THEIS, NEVILLE, MICHAEL J. BURKE, and OVERSTREET, concurring. CARTER took no part in the decision.)