People v. Galarza

This case presents question as to whether record contained sufficient evidence to support defendant’s conviction on failure to reduce speed to avoid accident. Appellate Court, in affirming defendant’s conviction, found that there was sufficient evidence to support defendant’s conviction, where witness stated that defendant was driving carelessly when he jerked steering wheel and caused car to hit tree, and where defendant’s blood alcohol content was more than twice legal amount. Appellate Court further noted that very fact that defendant hit tree established that he had failed to reduce speed to avoid said accident. Appellate Court also rejected defendant’s alternative argument that trial court improperly failed to give him admonishments under Rule 402 in instant stipulated bench trial, where Appellate Court found that such admonishments were not required, since defendant had preserved defense that he was not driving vehicle at time of accident.