Illinois Appellate Court
Criminal Court
Sufficiency of Evidence
Following a stipulated bench trial, defendant was found guilty of driving under the influence of alcohol and was sentenced to two years of court supervision. On appeal, defendant argued that the evidence was insufficient to sustain her conviction and that the stipulated bench trial was tantamount to a guilty plea, requiring admonishments pursuant to SCR 402. The appellate court agreed with the first contention and reversed, explaining that there was insufficient evidence to show that defendant was in actual physical control of a vehicle and that the State did not present evidence to support a conclusion that the defendant was intoxicated. (STEIGMANN and KNECHT, concurring)