People v. Steele

During late-night traffic safety check, officer pulled Defendant over for failing to wear seat belt, and asked him to pull to side so officer could write citation. Defendant hit accelerator, ran into officer, and sped off, and was later caught on foot. Officer's medical records showed that he was treated only for elbow and knee abrasions and released the same morning. Court erred in allowing officer's hearsay testimony of his diagnoses. State failed to prove element of great bodily harm beyond a reasonable doubt. Trial court's ruling on hearsay objection may be reviewed de novo when it does not involve fact finding or weighing credibility of witnesses. State failed to present evidence that Defendant was traveling at least 21 mph over speed limit as he fled police, and thus State failed to prove aggravated fleeing. (PUCINSKI and LAVIN, concurring.)