Case Review: People v. Greer, 2025 IL App (1st) 232302-U
By David Franks
Traffic Laws and Courts,
May 2026
(1) Defendant’s convictions for aggravated driving under the influence based on actual impairment were reversed where there was no evidence showing that defendant’s use of cannabis proximately caused the fatal crash. (2) There was no appellate jurisdiction to review the merits of defendant’s arguments with respect to two unsentenced, and therefore nonfinal, convictions for aggravated driving under the influence based on defendant’s THC concentration, requiring a remand for sentence on those counts. (3) Defendant’s conviction for reckless homicide was affirmed where evidence that defendant was traveling more than 90 miles-per-hour, combined with other circumstances, rationally supported the jury’s finding that his conduct was reckless, and where defendant’s remaining allegations of error either did not show an abuse of discretion or amount to clear and obvious error under the plain-error doctrine.
Case Summary: The City of Lake Forest v. Rey Martinez-Galarza, 2025 IL App (2d) 240352
By David Franks
Traffic Laws and Courts,
July 2025
A case summary of The City of Lake Forest v. Rey Martinez-Galarza, 2025 IL App (2d) 240352, holding the Arresting Officer did not unreasonably prolong the traffic stop of Defendant when the Arresting Officer explained the written warning to Defendant and smelled the odor of alcohol emanating from Defendant’s person.
No Video, No Discovery Violation
By David Franks
Traffic Laws and Courts,
October 2020
Absent evidence indicating that the state could have at one time produced an in-squad video and entire booking room video, and where the evidence did not prove that the recordings ever existed, the state did not commit a discovery violation.
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