People v. Way
89 N.E.3d 355
| Ill. | 2017Background
- On January 28, 2012, Ida Way crossed the center line and collided head‑on with another vehicle, causing great bodily harm and permanent disability to one victim and great bodily harm to her son.
- Urine tested positive for THC metabolite; a small bag of cannabis was found near Way; Way admitted prior drug use to police. She was charged with aggravated DUI under 625 ILCS 5/11‑501(a)(6), (d)(1)(C).
- At a stipulated bench trial the court barred defense evidence that a medical condition (low blood pressure) possibly caused Way to lose consciousness immediately before the crash.
- The trial court convicted Way of aggravated DUI and sentenced her to 18 months’ imprisonment; the appellate court reversed, holding the excluded evidence should have been admitted for the trier of fact.
- The Illinois Supreme Court granted review, held that a defendant may raise an affirmative defense that a sudden unforeseeable medical condition was the sole proximate cause, but reversed the appellate court because Way’s offer of proof was inadequate to establish sole proximate cause; conviction and sentence reinstated.
Issues
| Issue | Plaintiff's Argument (People) | Defendant's Argument (Way) | Held |
|---|---|---|---|
| Whether medical evidence that a sudden illness solely caused the crash is inadmissible in aggravated DUI under §11‑501(a)(6)/(d)(1)(C) | Martin controls: statute requires only that defendant drove with drugs in system and that driving proximately caused injuries; impairment is not required | Way argued she should be allowed to rebut the presumption by showing a medical emergency, not drug impairment, was the sole proximate cause | Court: Such an affirmative defense is permitted in principle; statutory scheme does not categorically bar it, but see below on burden |
| Who bears burden to prove a medical‑cause defense and its quantum | State argued strict‑liability per se offense limits such defenses | Way argued she could present evidence that medical condition, not drugs, caused crash | Held: Defendant bears burden to prove the medical condition was the sole proximate cause of the collision |
| Whether the trial court’s exclusion of Way’s evidence was reversible error | State relied on Martin and trial court’s exclusion as proper given per se nature of offense | Way contended exclusion denied her right to present a defense | Held: Exclusion as categorical rule was error, but reversal not warranted because Way’s offer of proof was insufficient |
| Adequacy of Way’s offer of proof to preserve claim | State asserted offer was vague and did not establish sole proximate cause | Way offered physician testimony only that low blood pressure "possibly" caused loss of consciousness and lay testimony that she appeared unimpaired | Held: Offer was conclusory and ambiguous; did not meet required specificity to show sole proximate cause, so exclusion was harmless and conviction reinstated |
Key Cases Cited
- People v. Martin, 2011 IL 109102 (holds certain DUI provisions are per se/strict‑liability; impairment need not be proven for §11‑501(a)(6)‑based aggravated DUI)
- People v. Quigley, 183 Ill. 2d 1 (statutory framework: misdemeanor DUI as underlying offense and aggravating factors elevate to felony)
- Holton v. Memorial Hospital, 176 Ill. 2d 95 (discusses sole proximate cause standard and proximate cause principles)
- People v. Hudson, 222 Ill. 2d 392 (analogies between civil and criminal proximate‑cause concepts)