People v. Martin
955 N.E.2d 1058
Ill.2011Background
- On December 25, 2004, the defendant's vehicle crossed the center line and head-on collided with an oncoming car, killing two people.
- The defendant was injured and, after hospitalization, provided two blood and urine samples; blood was alcohol/drug-free, urine showed methamphetamine and amphetamine.
- The defendant was indicted on one count of aggravated DUI under 625 ILCS 5/11-501(d)(1)(F).
- Eyewitnesses saw the crash; a reconstructionist and pathologist supported the fatal impact and high-energy nature of the collision.
- State expert Anderson testified methamphetamine was detected in the urine; Dr. Staubus testified the amount was not detectable/realistic, but acknowledged methamphetamine was present.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence for misdemeanor DUI | Martin violated 11-501(a)(6) by driving with any methamphetamine in urine. | Trace methamphetamine did not prove unlawful use; no impairment proven for the night of the accident. | Yes; State proved unlawful meth presence and driving. |
| Proximate cause for aggravated DUI | 11-501(d)(1)(F) requires only causal connection between driving and death, not impairment. | Must prove that drug use caused the deaths, not merely driving. | Proximate cause shown; driving with unlawful meth presence was proximate to deaths. |
Key Cases Cited
- People v. Fate, 159 Ill.2d 267 (1994) (drug-impaired driving statute aims to keep drug-impaired drivers off the road; no impairment standard for drug driving)
- People v. Quigley, 183 Ill.2d 1 (1998) (aggravated DUI is misdemeanor DUI with an aggravating factor; underlying act remains driving under the influence)
- People v. Merritt, 343 Ill.App.3d 442 (2003) (illustrates ambiguity when distinguishing impairment-based vs. strict-liability DUI in aggravation)
- Rodriguez, 398 Ill.App.3d 436 (2009) (unlawfulness of possession is inherent; no separate burden to prove precursor substances in drug tests)
- People v. Fate; Ziltz, Ziltz, 98 Ill.2d 38 (1983) (strict-liability driving with controlled substances; impairment not required)