People v. Steele, 19 N.E.3d 1084

Post-incident, Steele was stopped for a seat-belt violation at a late-night traffic safety checkpoint and fled after accelerating toward an officer, throwing the officer and leading to a chase across Chicago before Steele was apprehended on foot.
Steele was charged with two counts of attempted murder, one count of aggravated battery, and three counts of aggravated fleeing and eluding a peace officer in connection with the incident.
At trial, the officer testified to serious injuries; hospital records showed abrasions, while the officer later claimed torn ligaments and shoulder bone fragments not reflected in initial records.
The trial court acquitted Steele of attempted murder, convicted him of aggravated battery (requiring proof of great bodily harm) and all three aggravated fleeing counts, and sentenced him concurrently to nine years for aggravated battery and three years for each fleeing count.
On appeal, the State’s burden to prove ‘great bodily harm’ and the admissibility of the officer’s described injuries were central; the court reduced the aggravated battery to a battery, vacated two fleeing counts for lack of proof, and remanded for resentencing.
The court also addressed ineffective assistance and the need (or lack thereof) for a Krankel inquiry, ultimately concluding no per se conflict and no sua sponte Krankel remand were required.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence supported great bodily harm for aggravated battery	Steele; there was evidence of torn ligaments and severe injury	State failed to prove great bodily harm; hospital records lacked such injuries	No; great bodily harm not proven beyond reasonable doubt
Whether Porrata’s injury testimony was admissible expert testimony	Testimony showed torn ligaments; could be admitted as lay testimony	Medical diagnosis required expert testimony, not lay testimony	Testimony about torn ligaments inadmissible; required expert evidence
Ineffective assistance of counsel claims and Krankel procedures	Counsel may have failed to explore discovery and potential continuance; Krankel inquiry needed	No substantial evidence of ineffectiveness; no per se conflict	No reversible error; no sua sponte Krankel required
Sufficiency of evidence for counts IV and VI aggravated fleeing and eluding	Steele traveled over 21 mph; disobeyed two traffic signals	No evidence of 21 mph over limit or multiple signals; not proven	Counts IV and VI reversed; count V affirmed
Merger/one-crime issue with fleeing counts	All three counts should merge with the battery conviction	Evidence supports separate aggravated fleeing counts	Vacated two fleeing counts; affirmed one; remanded for resentencing on battery

People v. Virgil, 19 Ill. App. 3d 744 (1974) (concerning lesser included offenses in battery)
People v. Mays, 91 Ill. 2d 251 (1982) (definition of bodily harm in battery cases)
In re J.A., 336 Ill. App. 3d 814 (2003) (great bodily harm greater than abrasions; evidentiary standard)
People v. Ybarra, 156 Ill. App. 3d 996 (1987) (aggravation in sentencing; admissibility of later evidence)
People v. Cunningham, 212 Ill. 2d 274 (2004) (review standard for sufficiency of evidence; Jackson v. Virginia)
People v. Evans, 186 Ill. 2d 83 (1999) (deference to trial court credibility determinations)
People v. Beauchamp, 241 Ill. 2d 1 (2011) (due-process review of sufficiency of evidence)
Strickland v. Washington, 466 U.S. 668 (1984) (ineffective assistance standard; prejudice and deficiency)
People v. Virgil, 19 Ill. App. 3d 744 (1974) (see above)