People v. Czerwinski
1-12-32358
Ill. App. Ct.Mar 21, 2025Background
- Defendant Thomas Czerwinski was convicted of aggravated driving under the influence (DUI) of alcohol and reckless homicide after a fatal collision in which he made a left turn in front of a motorcycle ridden by Susan and Candido Esparza, resulting in Susan's death.
- Czerwinski's blood alcohol concentration (BAC) was tested at 0.195 grams per deciliter, well above the legal limit of 0.08, based on a hospital blood draw.
- Multiple eyewitnesses, police officers, bartenders, and medical experts testified regarding Czerwinski’s actions, alcohol consumption, and the accident circumstances.
- The defense challenged the admissibility of BAC evidence (improper medical technique), sufficiency of evidence regarding intoxication, and whether Czerwinski’s actions were a proximate cause of the death.
- The trial court found Czerwinski guilty and sentenced him to six years in prison; he appealed on evidentiary and sufficiency grounds.
Issues
| Issue | Defendant's Argument | State's Argument | Held |
|---|---|---|---|
| Admissibility of BAC evidence | Blood draw not performed using proper medical technique, so inadmissible | Procedure complied with standards; foundation for admissibility established | BAC evidence admissible |
| Sufficiency of evidence for intoxication | Evidence did not clearly show intoxication while driving | Overwhelming evidence of intoxication (high BAC, officer and witness testimony) | Evidence sufficient for conviction |
| Proximate cause of Susan Esparza’s death | No causal link between defendant’s driving under the influence and death | Collision directly caused by defendant’s impaired driving | Proximate cause sufficiently proven |
Key Cases Cited
- People v. Bush, 214 Ill. 2d 318 (forfeiture of arguments on appeal if not preserved at trial)
- Jackson v. Virginia, 443 U.S. 307 (standard for sufficiency of evidence claim)
- People v. Janik, 127 Ill. 2d 390 (intoxication is for trier of fact to decide)
- People v. Hudson, 222 Ill. 2d 392 (proximate cause requirements)
- Simmons v. Garces, 198 Ill. 2d 541 (legal causation and foreseeability)
- City of Chicago v. Beretta U.S.A. Corp., 213 Ill. 2d 351 (foreseeability in causation)
- People v. Ortiz, 196 Ill. 2d 236 (standard for reversing a conviction based on insufficiency of evidence)