People v. Jackson
983 N.E.2d 1027
Ill.2013Background
- Aaron Jackson was charged with driving while license suspended or revoked under 625 ILCS 5/6-303(a),(d) for an offense on July 9, 2010.
- The circuit court dismissed the charge as unconstitutional as applied to Jackson, and discharged him.
- The State appealed directly to the Illinois Supreme Court; the matter centers on whether the statute is constitutional or whether nonconstitutional grounds apply.
- Jackson had previously obtained a second license under a different name after his prior suspension, by answering a renewal form without disclosing the prior revocation.
- Evidence at issue concerns whether Jackson could present defense that he possessed a facially valid license and whether the State could rebut that defense by showing misrepresentation or noncompliance with restoration requirements.
- The Supreme Court vacated the circuit court’s dismissal and remanded for proceedings consistent with its opinion, clarifying the nonconstitutional issue and the scope of admissible defense evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the circuit court decided constitutional grounds or nonconstitutional grounds. | Jackson: court should consider nonconstitutional elements first. | State: constitutional issue must be resolved first if implicated. | Nonconstitutional grounds decision appropriate; remand required. |
| Whether defendant may present evidence that he possessed a valid license to challenge proof of the second element. | Jackson may introduce valid-license evidence to negate the second element. | State may rebut with misrepresentation or noncompliance to establish second element. | Defendant may present such defense evidence; State may rebut with fraud or noncompliance evidence. |
Key Cases Cited
- People v. Close, 238 Ill. 2d 497 (2010) (defines the two elements of driving with suspended license and admissibility of defense evidence)
- Turner, 64 Ill. 2d 183 (1976) (license revocation and restoration issues; defendant can challenge restoration)
- Waldron, 208 Ill. App. 3d 234 (1991) (explains Turner and defense to driving with revoked license)
- Papproth, 56 Ill. App. 3d 683 (1977) (unintentional errors and restoration context; honest confusion defense)
- Mulay, 225 Ill. 2d 601 (2007) (procedure for deciding constitutional issues on nonconstitutional grounds)
- In re E.H., 224 Ill. 2d 172 (2006) (nonconstitutional grounds preferred where possible)