Illinois Appellate Court
Criminal Court
Battery
Defendant was convicted, after bench trial, of aggravated battery and retail theft. A private security officer can qualify as a "merchant" under Section 12-4(b)(15), the aggravated battery of a merchant provision. Security officer, who wore uniform pants and jacket with security company's name on it, was an "independent contractor" of retail store and thus qualifies as a "merchant" under Section 16A-2.4. State did not need to prove that Defendant knew precise nature of security officer's employment relationship with store to prove that he knew he was a merchant. (GARCIA and McBRIDE, concurring.)