People v. Beck
90 N.E.3d 1083
| Ill. App. Ct. | 2017Background
- On Oct. 25–26, 2014, William Beck was in a head-on crash; he and the other driver (Alyssa Camp) were hospitalized. Beck was cited for DUI and later charged with aggravated DUI (driving with BAC ≥ 0.08 causing great bodily harm).
- Carle Hospital obtained a serum blood test shortly after Beck’s arrival showing 0.211; a law‑enforcement requested blood draw about 5½ hours later (ISP lab) showed whole‑blood BAC 0.071.
- Sheriff’s deputy Clough interviewed Beck in his hospital room (parents present), told him he would be charged with DUI, read a Warning to Motorist, did not give Miranda warnings, and requested the ISP blood draw; Beck made incriminating statements to Clough and medical staff documented he smelled of alcohol and reported drinking.
- Pretrial, Beck moved to suppress his hospital‑room statements (Miranda), to exclude the hospital blood test (arguing it was ordered at law‑enforcement request), to exclude the ISP blood test (arguing lack of probable cause), to bar retrograde‑extrapolation opinion testimony, and to prevent disclosure/use of broad hospital records and seat‑belt evidence.
- The trial court denied suppression (not custodial for Miranda), admitted the hospital blood under 625 ILCS 5/11‑501.4 (ordered by treating physician in ED, tested in hospital lab), found Clough had probable cause to request the ISP test, allowed retrograde extrapolation expert testimony (Frye satisfied and expert qualified), and excluded seat‑belt evidence as not defeating proximate‑cause under the aggravated‑DUI statute.
- Beck waived a jury and submitted a stipulated bench trial on count I; the court found him guilty of aggravated DUI (count II dismissed). Beck appealed; this opinion affirms.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Beck) | Held |
|---|---|---|---|
| Were Beck’s hospital‑room statements subject to Miranda suppression? | Statements were voluntary; hospital setting and presence of family/hospital staff meant Beck was not in custody. | Statements were elicited post‑arrest/after being told he would be charged and after issuance of citation/warning, so Miranda required. | Not custodial. Court affirmed denial of suppression: reasonable person could have felt free to leave; no formal arrest indicia. |
| Admissibility of hospital blood test under 625 ILCS 5/11‑501.4 | Test was ordered by treating ED physician in regular course of care and run in hospital lab; satisfies statutory foundation. | Test was effectively performed at law‑enforcement request or outside regular course of treatment; therefore inadmissible. | Admissible. Court found ED physician ordered test in course of treatment; hospital lab testing sufficed under statute. |
| Admissibility of law‑enforcement blood draw (ISP) — probable cause to request test? | Probable cause existed (scene investigation, eyewitnesses, EMT observations, hospital test result available) so officer could request chemical testing. | Officer lacked probable cause because hospital test/result disclosure was unauthorized; thus the ISP draw should be barred. | Admissible. Court held totality of circumstances (crash dynamics, witness/EMT observations, hospital info) provided probable cause; ISP test admissible. |
| Admissibility and reliability of retrograde extrapolation expert testimony | Retrograde extrapolation is generally accepted in toxicology; expert (Wetstein) was qualified and had adequate foundation (two blood draws, elimination rate, subject info). | Methodology is novel/unreliable without full foundational facts; expert made assumptions (e.g., empty stomach), so testimony should be barred under Frye/foundation rules. | Admissible. Court held retrograde extrapolation has general acceptance; Wetstein qualified; foundation adequate here (two blood draws permitted calculation of elimination rate). |
Key Cases Cited
- Miranda v. Arizona, 384 U.S. 436 (U.S. 1966) (custodial interrogation requires Miranda warnings)
- Berkemer v. McCarty, 468 U.S. 420 (U.S. 1984) (traffic stop/post‑arrest questioning and custodial context analysis)
- Frye v. United States, 293 F. 1013 (D.C. Cir. 1923) (general‑acceptance test for novel scientific evidence)
- People v. Vasquez, 393 Ill. App. 3d 185 (Ill. App. Ct. 2009) (hospital interview not custodial; factors for Miranda in hospital context)
- People v. Bahnfleth, 233 Ill. App. 3d 289 (Ill. App. Ct. 1992) (post‑field‑sobriety statements and the point at which a reasonable person would feel not free to leave)