People v. Davis
409 Ill. App. 3d 457
Ill. App. Ct.2011Background
- This is an Illinois appellate case reviewing a bench trial conviction for obstructing justice, with sentencing including a DNA fee.
- In December 2008, the State charged Davis with obstructing justice and two counts of aiding a fugitive; August 2009 bench trial resulted in a conviction on obstructing justice and acquittals on aiding fugitive counts, followed by sentence of 7 days in jail, 24 months probation, and a $200 DNA fee.
- At trial, the State relied on officers’ testimony that Davis lied about Bates’s presence in the house to delay Bates’s arrest; Bates was later found hidden in the home.
- Davis testified that Bates had been at the house to see the children, told him to leave, and that she delayed at the door due to pregnancy; she claimed consent to search was coerced during questioning.
- The trial court found the State’s version more credible and convicted Davis of obstructing justice; Davis challenged the sufficiency of the evidence and the DNA-fee credit.
- On appeal, the court held the evidence sufficient to sustain the obstructing-justice conviction and remanded to grant a $10 credit against the DNA fee for pretrial custody time, while affirming the judgment as modified and ordering costs.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of the obstructing-justice evidence | Davis argues the State failed to prove guilt beyond a reasonable doubt. | Davis contends her conduct did not impede the officers' investigation. | Sufficient evidence; rational trier could convict |
| DNA fee credit for pretrial custody | State concedes a $10 credit against the DNA fee is warranted for pretrial custody time. | Davis seeks any allowed credit against the DNA fee for time served pretrial. | Credit of $10 against DNA fee affirmed |
Key Cases Cited
- People v. Dat Tan Ngo, 388 Ill. App.3d 1048 (Ill. App. 3d 2008) (standard sufficiency review: rational trier of fact could find guilt beyond a reasonable doubt)
- People v. Gray, 146 Ill.App.3d 714 (Ill. App. 1st Dist. 1986) (recanation timing may affect obstructing-justice liability; original false information matters)
- People v. Comage, 241 Ill.2d 139 (Ill. 2011) (concealment and impediment; short-lived acts may still obstruct depending on evidence of impediment)
- In re M.F., 315 Ill.App.3d 641 (Ill. App. 2000) (evidence evaluation and impediment considerations relevant to obstruction cases)
- People v. Sumner, 40 Ill.App.3d 832 (Ill. App. 1976) (prior authorities on obstruction and destruction of evidence)
- People v. Brake, 336 Ill.App.3d 464 (Ill. App. 2003) (illustrates comparative analysis of impediment and concealment in obstruction)