People v. Way
2017 IL 120023
| Ill. | 2018Background
- On Jan. 28, 2012 Ida Way crossed the centerline and struck another vehicle, causing great bodily harm and permanent disability to one victim and great bodily harm to her son (passenger).
- Urine test after the crash detected THC metabolite; Way admitted recreational drug use to police. She was charged with aggravated DUI under 625 ILCS 5/11-501(a)(6) and (d)(1)(C).
- The trial court granted the State’s motion in limine and barred Way from presenting testimony that a sudden medical condition (low blood pressure) possibly caused loss of consciousness and the crash.
- The parties proceeded to a stipulated bench trial; the court found Way guilty of aggravated DUI and sentenced her to prison.
- The appellate court reversed, holding Way should have been allowed to present evidence that a sudden unforeseeable medical condition was the sole proximate cause of the accident; the Illinois Supreme Court granted review.
Issues
| Issue | State's Argument | Way's Argument | Held |
|---|---|---|---|
| Whether a defendant charged under §11-501(a)(6) may present evidence that a sudden unforeseeable medical condition was the sole proximate cause of a crash | Section 11-501(a)(6) is a per se (strict liability) offense; only a causal link between the physical act of driving and the injury is required, so medical-cause evidence is irrelevant | A defendant may rebut the presumption of impairment and present alternative (medical) causes showing the medical event was the sole proximate cause | The trial court erred to the extent it held such a defense categorically barred; a defendant may raise it as an affirmative defense but must prove the medical event was the sole proximate cause |
| Whether proof of impairment is required for aggravated DUI based on §11-501(a)(6) | Impairment need not be proved; statute presumes impairment when any amount of certain drugs is present | Way argued she could show non-impairment and an alternate cause | Court reaffirmed Martin: impairment is not an element when prosecution is based on presence of cannabis; the focus is on whether the driving was a proximate cause |
| Whether Way preserved a right to relief by offering adequate offer of proof about excluded medical evidence | N/A | Way offered at trial that her physician would testify low blood pressure might have caused loss of consciousness, and lay witnesses would testify she appeared unimpaired | Way failed to make an adequate, detailed offer of proof showing the medical condition was the sole proximate cause; exclusion of the evidence was therefore not reversible error |
| Procedural standard for reviewing trial court evidentiary rulings | Evidentiary rulings are reviewed for abuse of discretion; legal questions de novo | N/A | Court applied de novo review where legal interpretation controlled, but found error only in categorical bar—not reversible because of inadequate offer of proof |
Key Cases Cited
- People v. Martin, 2011 IL 109102 (per se DUI for certain drugs is strict liability; only physical act of driving need be causally linked to injury)
- People v. Quigley, 183 Ill.2d 1 (aggravating factors convert misdemeanor DUI to felony when underlying driving causes injury)
- Holton v. Memorial Hospital, 176 Ill.2d 95 (definition of sole proximate cause in tort law)
- People v. Hudson, 222 Ill.2d 392 (analogies between civil and criminal proximate-cause principles)
- People v. Peeples, 155 Ill.2d 422 (requirements for an adequate offer of proof)