People v. Brewer

2025 IL App (1st) 231352-U
CourtAppellate Court of Illinois
DecidedSeptember 5, 2025
Docket1-23-1352
StatusUnpublished

This text of 2025 IL App (1st) 231352-U (People v. Brewer) 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
People v. Brewer, 2025 IL App (1st) 231352-U (Ill. Ct. App. 2025).

Opinion

2025 IL App (1st) 231352-U No. 1-23-1352 Order filed September 5, 2025 Sixth Division

NOTICE: This order was filed under Supreme Court Rule 23 and is not precedent except in the limited circumstances allowed under Rule 23(e)(1). ______________________________________________________________________________ IN THE APPELLATE COURT OF ILLINOIS FIRST DISTRICT ______________________________________________________________________________ THE PEOPLE OF THE STATE OF ILLINOIS, ) Appeal from the ) Circuit Court of Plaintiff-Appellee, ) Cook County. ) v. ) No. 22 C3 30066 ) JAMES BREWER, ) Honorable ) Marc Martin, Defendant-Appellant. ) Judge, presiding.

PRESIDING JUSTICE C.A. WALKER delivered the judgment of the court. Justices Tailor and Gamrath concurred in the judgment.

ORDER

¶1 Held: We affirm defendant’s conviction for “aggravated driving under the influence of alcohol” where (1) the evidence was sufficient to prove he was impaired and (2) his claim of ineffective assistance of trial counsel was unpreserved for appellate review.

¶2 Following a bench trial, defendant James Brewer was found guilty of “aggravated driving

under the influence” of alcohol and sentenced to three years’ imprisonment. On appeal, defendant

argues that (1) the State failed to prove beyond a reasonable doubt he was impaired by alcohol and No. 1-23-1352

(2) trial counsel rendered ineffective assistance by failing to provide evidence of defendant’s

medical conditions and their adverse effect on his standardized field sobriety test (SFST)

performance. For the following reasons, we affirm.

¶3 BACKGROUND

¶4 Brewer was charged with multiple traffic offenses. The State proceeded on three counts of

“aggravated driving under the influence” of alcohol, which charged that he drove or was in actual

physical control of a motor vehicle while under the influence of alcohol and that, as the aggravating

factor, he had four prior driving under the influence or similar convictions (count I, Class 1 felony),

three such convictions (count II, Class 2 felony), and two such convictions (count III, Class 2

felony). 625 ILCS 5/11-501(a)(2), (d)(1)(A), (d)(2)(B)-(D) (West 2022).

¶5 At trial, Hanover Park police officer Ryan Rhode testified that he had been an officer for

four years and had received training on driving under the influence and traffic investigations. In

April 2021, he attended training to refresh his knowledge on SFSTs and signs of impairment.

¶6 On March 13, 2022, at approximately 6:10 p.m., Rhode responded to a vehicular crash with

injuries at the intersection of Lake Street and Barrington Road in Hanover Park, Illinois. He

observed two vehicles with “heavy damage” in the intersection and a white van east of the

intersection. After an investigation, he determined the van to be the at-fault vehicle. In court, he

identified Brewer as the driver of the white van.

¶7 Rhode and Brewer briefly conversed at the scene and then spoke in an ambulance. Brewer

had glossy, bloodshot eyes and an odor of alcohol on his breath. He told Rhode that he had

consumed a mimosa earlier in the day and ultimately refused treatment. Rhode then requested that

Brewer perform SFSTs, to which he agreed.

-2- No. 1-23-1352

¶8 SFSTs test for impairment and consumption of alcohol. Before the tests, Rhode asked

Brewer whether he had any medical conditions; Brewer stated that he had hypertension and some

pain in his left arm. Rhode opined that those conditions would not have affected Brewer’s

performance on the tests.

¶9 The first test was the horizontal gaze nystagmus (HGN) test. Prior to the test, Rhode

checked that Brewer’s eyes “tracked equally,” did not have “resting nystagmus,” and his pupils

were “equal size.” Rhode explained the test to Brewer, and Brewer acknowledged that he

understood. The HGN test has six clues, three for each eye. The clues are “lack of smooth pursuit,”

“distinct and sustained nystagmus at maximum deviation,” and “onset prior to 45.” Brewer

presented all six clues. Displaying four clues points to alcohol consumption.

¶ 10 The second test was the walk-and-turn test. The walk-and-turn test has eight clues. Rhode

explained the test to Brewer. Initially, he stated that he did not understand. After Rhode repeated

the instructions, Brewer stated that he understood. Brewer did not advise that he had any injuries

that prevented him from performing this test. He struggled to stand in the position instructed and

had to be shown the position multiple times. During the test, Brewer miscounted his steps, stepped

out of line, missed the heel to toe step, lost his balance, stepped backward, completed an improper

turn, and used his arms to balance, displaying seven clues in total. An individual displaying two

clues shows impairment.

¶ 11 The final test was the one-leg stand test. Rhode explained the test to Brewer, who

understood and stated that he had no medical reason why he could not perform the test. The one-

leg stand test has four clues. During the test, he put his foot down several times, used his arms for

-3- No. 1-23-1352

balancing, and swayed, displaying three clues in total. An individual displaying two clues shows

impairment.

¶ 12 Brewer was arrested after performing the SFSTs and taken to the police station. There, he

was read the warning to motorists and observed for 20 minutes prior to being asked to take a

breathalyzer, which he refused.

¶ 13 Rhode testified that he had seen individuals under the influence “hundreds of time[s]” in

his professional experience. Based on Brewer’s “poor driving,” his causing the vehicular accident,

his admission to consuming alcohol, the appearance of his eyes, the alcoholic odor on his breath,

his swaying, and his performance on the SFSTs, Rhode opined that Brewer was under the influence

of alcohol and impaired during the accident.

¶ 14 The State published the red light camera video from the intersection of Lake and Barrington

without objection. The video is part of the record on appeal and was reviewed by this court. In the

video, a white van crashes at a high rate of speed into two vehicles waiting at a light, pushing both

vehicles into the intersection. A man, whom Rhode identified as Brewer, comes into frame and

walks to the damaged vehicles. Two police vehicles then arrived.

¶ 15 Next, the State published, without objection, the dashcam video from the other responding

officer’s police vehicle, which captured Brewer performing the SFSTs. The video is part of the

record on appeal and was reviewed by this court. In the video, Brewer states that he does not have

“great balance” and has a “messed up” arm. He does not state that he has any injuries that would

prevent him from performing the tests. During the instruction phase of both the walk-and-turn and

the one-leg stand test, Brewer repeats the instructions given by Rhode multiple times and has the

instructions repeated to him at least twice. On the walk-and-turn test, Brewer miscounts his steps,

-4- No. 1-23-1352

steps out of line, stumbles slightly, steps backward, makes an improper turn, and lifts his arms

once. On the first attempt of the one-leg stand test, he lifts his leg for two seconds prior to putting

it on the ground. On his second attempt, he stumbles slightly, lifts his arms, stops counting out

loud despite being told to do so, and puts his foot on the ground prior to Rhode’s instructions.

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Bluebook (online)
2025 IL App (1st) 231352-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-brewer-illappct-2025.