People v. Baskerville
963 N.E.2d 898
Ill.2012Background
- Baskerville charged with obstructing a peace officer under 31-1(a) for lying about Christine's whereabouts.
- Deputy Dyke observed Christine driving on a suspended license; attempted to stop her; she went into her home when asked to return.
- Defendant spoke with Dyke outside the home, initially denying involvement, then offering that Christine could be found inside the house.
- Defense presented family testimony suggesting a Crothers-driven van and Christine's absence; State relied on Dyke's contemporaneous observations.
- Circuit court found both Baskerville and Christine guilty; appellate court reversed based on Raby's rule requiring a physical act; Court granted State's appeal.
- Holding: furnishing false information can constitute obstruction if it interposes an obstacle relevant to the officer's duties; in this case the State failed to prove impediment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does 31-1(a) require a physical act to obstruct? | People argue obstruction can be nonphysical under statute. | Baskerville argues obstruction requires a physical act per Raby. | Obstruction may be nonphysical; no required physical act. |
| Can knowingly furnishing false information constitute obstruction under 31-1(a)? | People contend false information can obstruct an officer. | Baskerville contends false information is not obstruction under 31-1(a). | Yes, false information may obstruct when it impedes duties. |
| Was Baskerville's false statement proven to impede Deputy Dyke's traffic stop? | People assert lies aided Christine in evading the stop. | Baskerville asserts no hindrance occurred; Dyke could proceed. | Evidence failed to prove that the false statement impeded the stop. |
Key Cases Cited
- People v. Raby, 40 Ill.2d 392 (1968) (initially constrained 31-1(a) scope; concerns about vagueness; physical act not strictly required)
- People v. Weathington, 82 Ill.2d 183 (1980) (addressed conduct between argument and physical act under 31-1(a))
- People v. Meyer, 44 Ill.2d 1 (1969) (illustrated obstruction beyond explicit physical acts)
- People v. Gordon, 408 Ill.App.3d 1009 (2011) (nonphysical obstruction at a traffic stop context)
- People v. Synnott, 349 Ill.App.3d 223 (2004) (repeated refusal to exit vehicle during stop as obstruction)