People v. Deroo
2022 IL 126120
| Ill. | 2022Background
- Defendant Ryan J. Deroo drove off a rural road, crashed his grandmother’s car, and was treated in a hospital emergency room after the accident.
- Emergency personnel and hospital staff observed signs of intoxication; a physician ordered a blood draw as part of emergency treatment.
- Hospital laboratory reported a very high serum alcohol result, converted to a whole‑blood BAC well above the legal limit.
- The State admitted the hospital chemical test results under 625 ILCS 5/11-501.4(a), which permits admission of emergency medical chemical tests as business records in DUI prosecutions.
- Deroo argued admission conflicted with Illinois Rule of Evidence 803(6), which (before this decision) excluded medical records from the business‑records hearsay exception in criminal cases; he sought reversal.
- The Supreme Court affirmed the convictions but held the statute and rule were in conflict and resolved the conflict by amending Ill. R. Evid. 803(6) to remove the criminal‑case medical‑records exclusion, making the hospital blood test admissible under the business‑records exception.
Issues
| Issue | State's Argument | Deroo's Argument | Held |
|---|---|---|---|
| Whether 625 ILCS 5/11‑501.4(a) conflicts with Ill. R. Evid. 803(6) | No — committee comments show rules were not intended to abrogate existing statutes; statute stands as separate emergency‑room exception | Yes — Rule 803(6) expressly excludes medical records in criminal cases, so the rule controls over a conflicting statute | Court: Texts conflict; court resolves conflict by amending Ill. R. Evid. 803(6) to remove the medical‑records exclusion, so statute and rule are reconciled and the blood test is admissible |
Key Cases Cited
- Wright v. Upson, 303 Ill. 120 (1922) (early Illinois common‑law rule excluding medical records from business‑records exception)
- People v. Walker, 119 Ill. 2d 465 (1988) (supreme court rule prevails over conflicting statute on matters within court authority)
- City of Chicago v. Old Colony Partners, 364 Ill. App. 3d 806 (2006) (explains business‑records rationale: records kept for business are likely trustworthy)
- Thomas v. Hogan, 308 F.2d 355 (4th Cir. 1962) (federal precedent discussing exclusion of medical opinions from business‑records exception)
- Long v. United States, 59 F.2d 602 (4th Cir. 1932) (treats medical diagnosis as factual observation for records admissibility)
- Beech Aircraft Corp. v. Rainey, 488 U.S. 153 (1988) (difficulty of drawing line between fact and opinion)
- Carmell v. Texas, 529 U.S. 513 (2000) (ordinary evidence‑rule changes do not implicate Ex Post Facto Clause)