People v. Martin
2011 IL 109102
| Ill. | 2011Background
- defendant Aaron Martin drove after leaving a Peoria bar; his car crossed the center line and two people died in the collision.
- blood and urine samples were collected; blood contained no alcohol or drugs, but urine tested positive for methamphetamine and amphetamine.
- Martin was indicted on one count of aggravated DUI under 625 ILCS 5/11-501(d)(1)(F).
- State presented eyewitness testimony of the accident, reconstruction findings, and a pathologist's account of victims' deaths; defense argued no impairment evidence.
- State's toxicology expert testified methamphetamine was present in urine but amount not quantified; defense toxicologist argued the amount was not detectable.
- Appellate court reversed the aggravated DUI conviction and remanded for misdemeanor DUI; this court reversed and reinstated the aggravated DUI conviction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether trace meth in urine proves unlawful use for aggravated DUI | Martin unlawfully used methamphetamine; trace amount suffices under 11-501(a)(6). | Trace amount does not prove unlawful use; causation to impairment is not required for the underlying offense. | Yes, sufficient to prove unlawful use for misdemeanor DUI; agitation extended to proximate cause analysis. |
| Whether proximate cause link between meth use and deaths is required | Proximate cause is between driving with any amount of drug and death; impairment not necessary. | The State must connect drug use to impairment causing the deaths. | Proximate cause required between driving and death; here, State proved driving with unlawful meth presence as proximate cause. |
| Whether the State proved aggravated DUI under 11-501(d)(1)(F) | The State established misdemeanor DUI and proximate death relationship, satisfying aggravator. | State failed to prove causation between drug use and deaths through impairment evidence. | Yes; aggravated DUI affirmed due to driving with unlawful meth presence causing the deaths. |
Key Cases Cited
- People v. Van Schoyck, 232 Ill. 2d 330 (2009) (aggravated DUI involves treating certain misdemeanors as felonies when enhanced by factors)
- People v. Quigley, 183 Ill. 2d 1 (1998) (aggravated DUI defined as felony when additional circumstances exist)
- People v. Fate, 159 Ill. 2d 267 (1994) (drug driving statute premised on no impairment standard; strict liability framework)
- People v. Merritt, 343 Ill. App. 3d 442 (2003) (discussed impairment versus non-impairment bases for proximate cause in aggravated DUI)
- People v. Rodriguez, 398 Ill. App. 3d 436 (2009) (unlawfulness element tied to unlawful use of a controlled substance)
- State v. Ziltz, 98 Ill. 2d 38 (1983) (strict liability driving with controlled substance in system)