People v. Espinoza

A charging instrument that identifies the victim of a nonsexual offense only as "a minor" is insufficient pursuant to Section 111-3 of Code of Criminal Procedure.  Courts properly dismissed criminal complaints based on insufficiency of those charging instruments.Under Section 111-3, State was required to identify the victims, and as State failed to amend charging instruments, and refused to identify victims by their names, initials, or any description of than "a minor", to strictly comply with Section 111-3 prior to trial, courts properly dismissed them. (GARMAN, FREEMAN, KILBRIDE, KARMEIER, BURKE, and THEIS, concurring.)