People v. Kladis, 355 Ill. Dec. 933

Kladis was arrested for DUI on May 3, 2008 by Northlake police officer Gaske.
On May 8, 2008, five days after arrest, she filed a Rule 237 petition and a Notice to Produce video for the summary suspension hearing.
June 3, 2008 hearing: State agreed to produce discovery including the video after defense Schmidt motion; tape existence confirmed.
Video recorded by in-car camera was erased at 4:24 a.m. on June 3, 2008, before initially scheduled court appearance.
Sanctions were imposed barring testimony about contents of the purged video; driving before arrest and post-arrest actions remained admissible.
Appellate court affirmed; Supreme Court granted State’s leave to appeal and affirmed the appellate decision.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is the in-car video recording discoverable in a misdemeanor DUI case?	Kladis argued Schmidt's scope is broad enough to include video recordings.	State argued Schmidt limited discovery and excluded video recordings; no obligation to preserve.	Video recordings are discoverable in misdemeanor DUI cases.
Was the sanction for destruction of the video reasonable?	Sanction appropriate to remedy discovery violation and preserve truth-seeking process.	Sanction too harsh, effectively dismissing key evidence of DUI.	Sanction was reasonable; narrowly tailored and not an abuse of discretion.

People v. Schmidt, 56 Ill. 2d 572 (1974) (defined discovery scope in misdemeanor cases)
People v. Morgan, 112 Ill.2d 111 (1986) (abuse of discretion standard for sanctions)
Krupp v. Chicago Transit Authority, 8 Ill.2d 37 (1956) (relevance and discovery principles for evidence)
Bauter v. Reding, 68 Ill.App.3d 171 (1979) (relevancy and materiality in discovery)
People v. Taylor, 2011 IL 110067 (2011) (admissibility of video recordings in DUI cases)
D.C. v. S.A., 178 Ill.2d 551 (1997) (pretrial discovery and truth-seeking objective)
Scott v. Harris, 550 U.S. 372 (2007) (video evidence clarifies factual record)