People v. Baskerville
2012 IL 111056
| Ill. | 2012Background
- Defendant Baskerville was charged with obstructing a peace officer under 720 ILCS 5/31-1(a) for lying about his wife Christine's whereabouts during an attempted traffic stop.
- The State alleged that Baskerville knowingly obstructed Deputy Dyke by providing false information as to Christine's location, impeding the officer's authorized traffic-stop duties.
- The circuit court found Baskerville and Christine Baskerville guilty; they were sentenced to 90 and 150 days respectively.
- The appellate court reversed, holding obstruction under 31-1(a) requires a physical act and that false information is not an obstruction.
- The majority holds that obstruction does not require a physical act and may include false information if it interposes an obstacle relevant to the officer's duties, but the State failed to prove obstruction in this case.
- The decision affirms the appellate court judgment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does obstruction of a peace officer under 31-1(a) require a physical act? | People argues physical act is not required; broad interpretation includes nonphysical interference. | Baskerville contends only physical acts qualify under 31-1(a) per Raby. | No; the statute does not require a physical act. |
| Can knowingly furnishing false information constitute obstruction under 31-1(a)? | People contends false information can impede the officer's duties. | Baskerville argues lies cannot be obstruction. | Yes, if it interposes an obstacle hindering the officer's duties. |
| Was the State's evidence sufficient to prove Baskerville obstructed Deputy Dyke? | State asserts Baskerville's lies delayed or prevented the traffic stop. | State failed to show the lies impeded the officer’s authorized act. | The evidence was insufficient to prove obstruction beyond a reasonable doubt. |
| What is the role of Raby and related cases in interpreting 31-1(a)? | Raby supports a narrower, physical-act-based reading. | Raby is distinguishable; obstruction includes nonphysical acts. | Raby does not control here; obstruction can include nonphysical conduct. |
Key Cases Cited
- People v. Raby, 40 Ill. 2d 392 (Il. 1968) (limited to physical acts in resisting arrest; not controlling on false information)
- People v. Weathington, 82 Ill. 2d 183 (Il. 1980) (recognized nonphysical conduct may fall within obstructing)
- People v. Meyer, 44 Ill.2d 1 (Il. 1969) (refusal to move may constitute obstruction)
- People v. Gordon, 408 Ill. App. 3d 1009 (Il. App. 2011) (nonphysical conduct can obstruct duties)
- People v. Synnott, 349 Ill. App. 3d 223 (Il. App. 2004) (repeated refusal to exit vehicle can obstruct)
- People v. Meister, 289 Ill. App. 3d 337 (Il. App. 1997) (furnishing false information as obstructive)
- People v. Gibbs, 115 Ill. App. 2d 113 (Il. App. 2d 1969) (lies to suspects impede arrests)
- People v. Hilgenberg, 223 Ill. App. 3d 286 (Il. App. 1991) (false information may have legal significance)
- People v. Jones, 223 Ill. 2d 569 (Il. 2006) (avoid redundancy in interpreting statute)