People v. Willis
2025 IL App (4th) 231345-U
Ill. App. Ct.2025Background
- Sherman M. Willis was stopped by Lincoln Police Corporal Daniel Carr after driving over the fog line multiple times and speeding.
- During the traffic stop, Carr observed a jar of cannabis in Willis’s vehicle and asked him to exit the car for a probable-cause-based search; Willis repeatedly refused to comply.
- Willis locked his doors and rolled up his window despite multiple orders to exit, leading police to break his window and physically remove him.
- Willis was charged with obstructing a peace officer under 720 ILCS 5/31-1, convicted by a jury, and sentenced to 30 days in jail, probation, and fines.
- On appeal, Willis argued insufficiency of the evidence that he materially impeded the officer and alleged a faulty jury instruction for not explicitly requiring proof of material impediment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of Evidence for Obstructing a Peace Officer | Willis materially impeded Carr’s duties by refusing to exit and locking his car | The impact on Carr’s duties was minimal and too brief to constitute obstruction | Evidence was sufficient to prove material impediment |
| Jury Instruction on "Materially Impeded" Requirement | Pattern instruction given accurately conveyed the law | Omission failed to make the jury require material impediment beyond a reasonable doubt | No error; pattern instructions were adequate |
| Forfeiture of Jury Instruction Argument | N/A | Did not object or offer alternate, but substantial rights were at stake | Forfeited; not plain error under the facts |
| De minimis (minimal delay) exception | Refusal significantly hindered Carr, not de minimis | Delay was trivial and did not rise to obstruction | Conduct was more than de minimis—it materially obstructed |
Key Cases Cited
- People v. Baskerville, 2012 IL 111056 (Illinois Supreme Court) (obstructive conduct must actually hinder or impede an officer’s authorized act)
- People v. Synnott, 349 Ill. App. 3d 223 (Ill. App. Ct. 2004) (refusal to exit vehicle is obstruction due to officer safety)
- People v. Taylor, 2012 IL App (2d) 110222 (Illinois Appellate Court) (minimal or brief delay does not constitute material impediment)
- People v. Mehta, 2020 IL App (3d) 180020 (Illinois Appellate Court) (materiality is implicit in obstruction statutes)