People v. Casler, 130 N.E.3d 566

Defendant Rasheed Casler was charged with obstructing justice for giving a false name ("Jakuta King Williams") to Sgt. Guy Draper when officers encountered him at a hotel room on March 6, 2015.
Officers in uniform smelled marijuana coming from room 210; when a man in a green hoodie briefly stepped into the hallway, he looked at officers and retreated into the room.
Draper knocked, identified himself as a police officer, and asked who was in the bathroom; the defendant replied he was "defecating" and later gave the false name when asked to identify himself.
After the defendant emerged, officers recognized him, learned he had an outstanding warrant, arrested him, and later found his ID in a hoodie on the bed.
At trial the defendant admitted giving the false name but claimed he thought friends were joking and did not know police were present or that he had a warrant; the jury convicted him of obstructing justice.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence proved Casler acted with intent to prevent his apprehension by giving a false name	Testimony and circumstances (eye contact with uniformed officers, retreat to bathroom, Draper identifying himself, defendant's false name and claim of no ID) support inference of intent	Casler contended he was ill/intoxicated, thought friends were joking, did not know police were present or he had a warrant, so lacked intent	Court affirmed: intent can be inferred from surrounding circumstances; jury reasonably found intent to avoid arrest
Whether providing the false name materially impeded administration of justice	False information can immediately impair investigation; Draper was initially fooled and only learned true identity after further inquiry	Defendant argued any delay was de minimis and authority (Taylor/Comage) requires material impediment	Court rejected Taylor’s extension of Comage; followed authorities holding false identification can constitute obstruction even if delay is brief; affirmed conviction

People v. Comage, 241 Ill. 2d 139 (Sup. Ct. Ill.) (narrowly construing "conceal" under obstructing-justice statute and requiring analysis of whether evidence was materially concealed)
People v. Baskerville, 2012 IL 111056 (Ill. 2012) (false statements to police may obstruct where they interpose an obstacle relevant to officer duties)
People v. Davis, 409 Ill. App. 3d 457 (4th Dist. 2011) (affirming obstruction conviction for knowingly furnishing false information; Comage not controlling for false statements)
People v. Childs, 272 Ill. App. 3d 787 (4th Dist. 1995) (false statement to police to prevent apprehension of another supports obstruction conviction)
People v. Saxon, 374 Ill. App. 3d 409 (1st Dist. 2007) (standard for reviewing sufficiency of the evidence and allowing reasonable inferences for prosecution)
People v. Witherspoon, 379 Ill. App. 3d 298 (4th Dist. 2008) (intent is a state of mind that may be proved by circumstantial evidence)