People v. Kladis
2011 IL 110920
Ill.2011Background
- Defendant Marina Kladis was arrested for DUI in Northlake, Illinois.
- Defendant filed Rule 237 request and a summary-suspension petition seeking production of the squad-car video.
- The State destroyed the in-car video recording before trial; sanctions were imposed barring testimony about the tape.
- Trial court found the videotape was discoverable and sanctioned the State for destruction, limiting testimony to events outside the purged portion.
- Appellate Court affirmed; the State sought review, and the Illinois Supreme Court affirmed, remanding for further proceedings.
- The Court held that squad-car video recordings are discoverable in misdemeanor DUI cases and that the sanctions were proper and narrowly tailored.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is the squad-car video recording discoverable in a misdemeanor DUI case? | Kladis (People): Schmidt limited discovery in misdemeanors is outdated; video is relevant. | Kladis (defense) challenged destruction; broader discovery should apply under modern practice. | Yes; video recordings are discoverable in misdemeanor DUI cases. |
| Was the destruction of the video a sanctionable discovery violation? | Kladis argues sanction appropriate given notice to preserve. | Kladis contends destruction was not sanctionable in a misdemeanor case. | Yes; sanction for destruction was proper. |
| Was the sanctions order appropriately tailored and not a complete preclusion of evidence? | Sanction limited testimony about content of video from five seconds before stop to arrest. | Sanction improperly barred all evidence of DUI guilt. | Sanction properly narrowly tailored; did not bar all relevant proof. |
Key Cases Cited
- People v. Schmidt, 56 Ill.2d 572 (1974) (limited discovery in misdemeanor cases; list of discoverable items then available)
- People v. Morgan, 112 Ill.2d 111 (1986) (abuse-of-discretion standard for sanctions; trial court weighs impact of violation)
- Koutsakis v. Chicago Transit Authority, 255 Ill. App.3d 306 (1993) (trial court discretion in sanctions for discovery violations)
- Krupp v. Chicago Transit Authority, 8 Ill.2d 37 (1956) (pretrial discovery broadens beyond strict statutory list when relevant to issues)
- People v. Ramsey, 239 Ill.2d 342 (2010) (abuse-of-discretion standard for sanctions; substantial discretion to trial court)
- People v. Taylor, 2011 IL 110067 (2011) (admissibility of video evidence; reaffirmed general admissibility of squad-car videos)
- Scott v. Harris, 550 U.S. 372 (2007) (video evidence can illuminate the truth at issue in appellate review)