2022 IL App (1st) 200598
Ill. App. Ct.2022Background
- On July 21, 2018, Adam Grunin (driving a white Hyundai) struck a stopped Chevrolet Equinox at a red light; passenger Alyssa Lendino died and two others were seriously injured. Grunin had earlier lightly collided with another vehicle and continued driving.
- Event-data/airbag control module (ACM) records showed Grunin’s vehicle traveled ~0.6 mile in 27–29 seconds and accelerated from ~100.6 to 107.5 mph in the five seconds before impact; no pre-impact braking or steering inputs >5° were recorded.
- State witnesses (eyewitnesses, police, and a reconstruction expert, Sgt. Ashleman) testified Grunin was speeding, maintained lane, accelerated, and was in control immediately before the collision.
- Defense presented reconstruction expert Roger Barrette (arguing possible lack of steering/braking input and possible automatic vehicle alignment) and neurologist Dr. Andres Kanner (opining Grunin likely suffered a focal temporal‑lobe seizure with loss of awareness sometime after the first collision and before the fatal impact).
- Jury convicted Grunin of reckless homicide and two counts of aggravated reckless driving; convictions merged and he was sentenced to concurrent prison terms (four years for reckless homicide). Grunin appealed, arguing insufficiency of the evidence because a seizure (per Dr. Kanner) explained the failure to brake or avoid the collision.
Issues
| Issue | Plaintiff's Argument (People) | Defendant's Argument (Grunin) | Held |
|---|---|---|---|
| Sufficiency of evidence to prove reckless homicide and aggravated reckless driving | Evidence (ACM data, eyewitnesses, reconstruction expert) established volitional speeding, acceleration, failure to brake or veer, and control of vehicle → recklessness proven beyond a reasonable doubt | Dr. Kanner’s unrebutted opinion that Grunin suffered a focal seizure (loss of awareness) before impact explains lack of avoidance; conviction not sustainable | Affirmed — viewing evidence in light most favorable to State, a rational juror could find elements proven beyond a reasonable doubt |
| Whether an unrebutted expert medical opinion that defendant had a seizure required acquittal | The jury may reject defense expert testimony; absence of State medical rebuttal does not bind the trier of fact | Defense contends expert opinion was dispositive and uncontradicted, removing voluntariness from issue | Held for State — jury weighed conflicting expert and lay evidence and reasonably credited State’s reconstruction testimony over defense medical theory |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (establishes sufficiency-of-the-evidence standard)
- People v. McLaurin, 2020 IL 124563 (Illinois standard for reviewing sufficiency of evidence)
- People v. Barham, 337 Ill. App. 3d 1121 (definition of recklessness; inference from circumstances)
- People v. Moreno, 116 Ill. App. 3d 1 (excessive speed + failure to brake supports reckless homicide)
- People v. Boyle, 78 Ill. App. 3d 791 (similar principles: speed and failure to brake)
- People v. Dresher, 364 Ill. App. 3d 847 (trier of fact may discredit defense expert testimony)
- People v. Mancinelli, 232 Ill. App. 3d 211 (excessive speed in nonemergency tends to show conscious disregard)
- People v. Bradford, 2016 IL 118674 (factfinder resolves conflicts; credibility determinations binding on review)