2019 IL App (3d) 160643
Ill. App. Ct.2019Background
- Defendant Luis J. Sanchez was charged with DUI for being in actual physical control of a motor vehicle while under the influence of alcohol.
- A vehicle registered to Sanchez was found driven onto a raised median on a bridge and abandoned; Sanchez lived about 3½ blocks away.
- Officer Mau found Sanchez at his home later that night; Sanchez exhibited glassy eyes, slurred speech, stumbling, and smelled of alcohol, and he possessed the vehicle keys.
- A squad-car video recorded Sanchez admitting he had been drinking (a bottle of wine and multiple beers) at a restaurant (Puerto), that he drove home and drove onto the median, and that he walked home after the collision; he refused field sobriety and chemical tests.
- At bench trial the court convicted Sanchez of DUI and sentenced him to a conditional discharge, fines/costs, and community service.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the State sufficiently corroborated Sanchez’s out-of-court statements under the corpus delicti rule so those statements could be used to prove DUI | The independent evidence (vehicle registered to Sanchez, keys in his possession, his proximity to crash, signs of intoxication when contacted) corresponded to his admissions and tend to connect him to the offense | Sanchez argued his statements about drinking before driving were uncorroborated; the only proof he drank prior to driving was his own admissions on video, insufficient under corpus delicti | Affirmed: independent evidence sufficiently corroborated Sanchez’s admissions under the corpus delicti rule; court could consider the admissions with other evidence to find guilt beyond a reasonable doubt |
Key Cases Cited
- People v. Lara, 2012 IL 112370 (explaining corpus delicti requires independent corroboration of confessions and the corroboration need only tend to show the commission of a crime)