People v. Rogers

Illinois Appellate Court
Criminal Court
DUI
Citation
Case Number: 
2020 IL App (3d) 180088
Decision Date: 
Thursday, May 7, 2020
District: 
3d Dist.
Division/County: 
Will Co.
Holding: 
Reversed.
Justice: 
O'BRIEN

Defendant was convicted, after stipulated bench trial, of DUI(a)(6). Compulsory joinder can apply to misdemeanor charges that are initially filed by a police officer.Defendant was initially charged with DUI(a)(4) by citation and complaint filed by officer in 12/2015, which derived from officer's investigation and interaction with Defendant at scene of auto accident; State filed subsequent DUI(a)(6) charge more than 4 months later. Officer could have filed both charges in 12/2015. Thus, the 2 charges are subject to compulsory joinder. Defense counsel was ineffective by failing to assert a violation of his right to a trial within the statutorily prescribed 160-day period. Counsel's inaction altered the outcome of the case because counsel could have moved to dismiss the one charge that Defendant was convicted of, DUI(a)(6). (LYTTON and HOLDRIDGE, concurring.)