People v. Galarza, 2023 IL 127678

In August 2016 Galarza was charged with two counts of DUI, one count of failure to reduce speed to avoid an accident (625 ILCS 5/11-601(a)), and one count of operating an uninsured motor vehicle arising from a single-vehicle crash into a tree at about 5 a.m. on August 27, 2016.
The case proceeded as a stipulated bench trial: the court considered the responding officer’s report, Wilmington Fire Protection District patient-care reports, and the vehicle registration.
Stipulated facts: paramedics found Jordan Taylor in the driver’s seat and told them Galarza (her boyfriend) jerked the wheel and hit the tree; an empty vodka bottle was found in the front passenger-floor area; Galarza’s phone was wedged in the driver’s seat; Officer Albin observed signs of intoxication and a PBT of .203; Galarza admitted to the officer that he was the driver.
Defense argued at the bench trial that Taylor, not Galarza, was the driver and therefore the stipulation did not admit guilt; the court nonetheless found Galarza guilty of DUI, failure to reduce speed to avoid an accident, and operating an uninsured vehicle.
On appeal the Third District affirmed the failure-to-reduce-speed conviction, reversed the uninsured-vehicle conviction (State conceded error), and held the stipulated bench trial was not tantamount to a guilty plea because Galarza preserved a defense; the Illinois Supreme Court affirmed.

Issue	State's Argument	Galarza's Argument	Held
Sufficiency of evidence for failure to reduce speed to avoid an accident	Circumstantial evidence (high BAC .203, jerking the wheel, heavy front-end damage, airbag deployment) allowed a reasonable inference of careless driving and failure to reduce speed	Evidence only shows intoxication and an unexplained jerk of the wheel; collision alone cannot establish failure to reduce speed	Affirmed: viewed in State’s favor, circumstantial evidence was sufficient to prove both carelessness and failure to reduce speed
Whether stipulated bench trial was tantamount to a guilty plea requiring Rule 402(a) admonitions	Stipulation did not admit guilt; defendant and counsel preserved a defense (claimed Taylor was the driver), so Rule 402(a) admonitions were not required	Counsel effectively failed to present a real defense (only denied stipulated facts), so the stipulation was tantamount to a guilty plea and Rule 402(a) admonitions were required	Affirmed: stipulation was not tantamount to a guilty plea because defense preserved an issue of fact (who was driving); no Rule 402(a) admonishments required; issue forfeited but no plain error

People v. Clendenin, 238 Ill. 2d 302 (2010) (stipulated bench trial is tantamount to a guilty plea only in two specified circumstances)
People v. Horton, 143 Ill. 2d 11 (1991) (trial court must give guilty-plea admonishments when stipulated bench trial is tantamount to a plea)
People v. Hall, 194 Ill. 2d 305 (2000) (circumstantial evidence may sustain a conviction if it proves elements beyond a reasonable doubt)
People v. Wawczak, 109 Ill. 2d 244 (1985) (definition of due care under Vehicle Code)
People v. Brant, 82 Ill. App. 3d 847 (1980) (held collision alone insufficient to infer failure to reduce speed)
People v. Sampson, 130 Ill. App. 3d 438 (1985) (same proposition as Brant)