People v. Taylor
2012 IL App (2d) 110222
Ill. App. Ct.2012Background
- Defendant Taylor was arrested on a De Kalb County warrant after giving a false name and later stating he had no ID.
- Officer Mott confirmed the warrant and confronted Taylor with the false name; Taylor identified himself later and cooperated.
- Taylor was arrested within 5–10 minutes; identification was found only after arrest.
- Taylor testified he lied to avoid court inconvenience; he claimed cooperation thereafter and denied resisting arrest.
- Taylor was convicted of obstructing justice (furnishing false information) but acquitted of resisting a peace officer; judgment reversed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether false information constitutes obstruction of justice given it did not materially impede the investigation | Taylor's false name did not materially impede arrest | False statements do not amount to obstruction under Comage/Baskerville | Conviction reversed; no material impediment found |
| Whether the evidence shows actual interference to support obstruction of justice | State argues risk/impedance supported conviction | No actual interference; delay was minimal | Conviction reversed for lack of actual interference |
| Whether BaskervilleComage-Davis framework dictates reversal here | Davis shows potential impediment; Comage precedent applies | Baskerville clarifies requirement of actual impediment | Court adopts Baskerville/Comage standard; Taylor's conduct did not obstruct |
Key Cases Cited
- People v. Comage, 241 Ill. 2d 139 (2011) (brief concealment not necessarily obstructive; actual interference required)
- People v. Davis, 409 Ill. App. 3d 457 (2011) (false statements may create risk but not always actual interference)
- People v. Baskerville, 2012 IL 111056 (2012) (false statements may obstruct if they actually impede officer duties)
- People v. Ellis, 199 Ill. 2d 28 (2002) (false names during stops; attempted obstruction context)
- People v. Remias, 169 Ill. App. 3d 309 (1988) (relevance to obstruction charges in prior context)