Beckham v. Petermann

2025 IL App (5th) 240623
CourtAppellate Court of Illinois
DecidedOctober 10, 2025
Docket5-24-0623
StatusPublished

This text of 2025 IL App (5th) 240623 (Beckham v. Petermann) is published on Counsel Stack Legal Research, covering Appellate Court of Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Beckham v. Petermann, 2025 IL App (5th) 240623 (Ill. Ct. App. 2025).

Opinion

Order filed September 11, 2025. 2025 IL App (5th) 240623 Motion to publish granted October 10, 2025. NO. 5-24-0623

IN THE

APPELLATE COURT OF ILLINOIS

FIFTH DISTRICT ______________________________________________________________________________

STEVEN BECKHAM, ) Appeal from the ) Circuit Court of Plaintiff-Appellant, ) Madison County. ) v. ) No. 19-L-381 ) DONALD PETERMANN, ) Honorable ) Christopher P. Threlkeld, Defendant-Appellee. ) Judge, presiding ______________________________________________________________________________

PRESIDING JUSTICE McHANEY delivered the judgment of the court, with opinion. Justices Barberis and Vaughan concurred in the judgment and opinion.

OPINION

¶1 This case involves a motor vehicle accident which occurred because Donald Petermann

(Petermann) did not properly secure furniture on a trailer being pulled by his vehicle. The furniture

items fell into the path of a van being driven by Steven Beckham (Beckham). When Beckham

slowed down to avoid hitting the furniture, he was rear-ended by a semi-trailer truck (hereafter

“semi”). The trial court granted Beckham’s summary judgment motion on the issue of liability.

The jury returned a verdict in favor of Petermann. From the denial of his posttrial motion, Beckham

timely appealed. On appeal, Beckham claims that he was prejudiced by the improper introduction

of extraneous information during voir dire and that the jury was improperly instructed. He also

claims that the trial court erred by denying his motion for judgment notwithstanding the verdict

(judgment n.o.v.) or alternative motion for a new trial. For the following reasons, we affirm.

1 ¶2 I. BACKGROUND

¶3 The motor vehicle accident occurred on February 3, 2018, on Interstate 270 in Madison

County. Furniture items became dislodged from a trailer being pulled by Petermann’s vehicle and

spilled onto the highway. When Beckham slowed down to avoid hitting those items, he was rear-

ended by a semi. Petermann did not see this impact and denied that it occurred.

¶4 Before trial, Beckham filed a motion for partial summary judgment on the issue of liability.

On February 6, 2024, the trial court entered a written order ruling on various motions in limine and

objections to portions of the evidence deposition of plaintiff’s medical expert. Included in this

order, was the following sentence: “Plaintiff’s motion for summary judgment is granted as to

liability.” At the jury trial, before voir dire, the court and counsel discussed the proper wording of

the statement of the case to be read to the venire. Petermann argued that the court’s prior summary

judgment ruling on liability did not automatically make him liable for damages. He contended that

the jury should have the option to find that Beckham’s claimed injuries/damages were not

proximately caused by his negligence. Beckham responded that the court should now grant

summary judgment on the issue of “causation of injuries,” and the jury should only be instructed

to consider the amount of damages to be awarded. The trial court clarified its previous ruling on

liability as follows:

“So what I did at our final pretrial was I ruled that the accident was caused by

[Petermann], that the chain reaction of the load spilling onto the road caused the accident.

I have not gotten into the issue of damages on that, so the issue of damages is still for

determination by the jury.

So what we are going to do is defendant—it’s found that [Petermann] is liable and

negligent for causing the accident and that the jury will be required to decide the nature

2 and extent of the damage. [Petermann] disputes the nature and extent of the damages

caused by the accident.”

The statement of the case that was read to the venire included the following: “[Petermann] denies

the nature, extent, and duration of injuries claimed by [Beckham]. As the party bringing the

lawsuit, [Beckham] has the burden of proof.”

¶5 Before voir dire began, Beckham’s attorney asked the trial court to excuse prospective

juror number 15 (hereafter “juror 15”) because she knew Beckham, and he therefore presumed

that Petermann would want juror 15 removed for cause, because she would likely favor Beckham.

Beckham’s attorney failed to tell the court that juror 15 was the sister of Beckham’s ex-wife,

against whom Beckham had recently prevailed in a “very horrible custody battle.” The trial court

denied the request to excuse juror 15 at that time.

¶6 During voir dire, the trial court asked if any prospective jurors knew the parties and/or their

attorneys. The following colloquy occurred in the presence of the venire:

“THE COURT: Anybody else know the plaintiff or the plaintiff’s counsel? So

[juror 15], what is your relationship to the plaintiff—you know him. Do you see him often?

PROSPECTIVE JUROR 15: I don’t see him often, no, but my opinion of him is

not that great, so it’s probably not best if I am on the jury.

THE COURT: So would you say for that reason you’re predisposed to disbelieve

what [he] has to say?

PROSPECTIVE JUROR 15: Probably. I don’t want to be like that, but I mean, I

can’t—just from what I know from myself, I don’t—I can’t trust what he says.”

Sometime later, prospective juror number 14 (hereafter “juror 14”) asked to speak with the judge

in private. Outside the presence of the venire, juror 14 told the court that he might be influenced

3 by what juror 15 said. In response to further inquiry by the court, juror 14 stated that if he was

chosen, he would follow the court’s instructions. Ultimately, the trial court struck both juror 14

and juror 15 for cause.

¶7 Beckham’s attorney made a motion to dismiss the entire “array” 1 because of the statements

of juror 15, asserting: “[S]ince she’s said that I wouldn’t believe anything [Beckham] says, since

she’s already commented to the whole array as to his credibility, I think the whole array has been

poisoned.” Petermann objected to the request, arguing that juror 15’s statements were her personal

opinions. The trial court denied Beckham’s request.

¶8 During opening statement, Petermann’s attorney informed the jury that though the trial

court ruled that Petermann’s negligence caused the impact between his van and the semi, Beckham

had the burden to prove that the accident caused him injuries. Petermann testified at trial that he

did not see the impact between Beckham’s van and the semi. He observed Beckham and his

passenger walking around the scene of the accident, and Beckham did not appear to be injured.

¶9 Petermann testified that Beckham said he was not hurt, and Beckham’s passenger smirked

and motioned to his back. Then, both Beckham and his passenger complained that their backs hurt,

which Petermann testified seemed “fake.” Petermann testified that he thought their behavior was

suspicious and did not believe either individual was injured. The following colloquy occurred:

“Q. Do you think that they were pretending to be hurt, or were they walking in

already hurt? Which is it? Tell the jury.

A. When they got out of the van, I heard giggling, and they come to the back

of the van and stood in front of me. And I asked them if they were both all right, and

1 Counsel used interchangeably the words “array” and “panel.” We deduce he meant the entire venire. 4 they said yes. And then the passenger motioned oh, my back, and then right away the

driver said the same thing.

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Bluebook (online)
2025 IL App (5th) 240623, Counsel Stack Legal Research, https://law.counselstack.com/opinion/beckham-v-petermann-illappct-2025.