People v. Garcia

2023 IL App (1st) 192226-U
Procedural entryThis page is a short order in People v. Garcia. Read the opinion of the Court — 236 N.E.3d 488
Appellate Court of Illinois·Decided June 30, 2023·No. 1-19-2226·Unpublished

Opinion

2023 IL App (1st) 192226-U

No. 1-19-2226

Order filed June 30, 2023

FIFTH 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 JUDICIAL DISTRICT

) Appeal from the THE PEOPLE OF THE STATE OF ILLINOIS, ) Circuit Court of ) Cook County. Plaintiff-Appellee, ) ) No. TN 516169 v. ) ) Honorable TERRY GARCIA, ) Kerrie Maloney Laytin, ) William Yu, Defendant-Appellant. ) Lori Rosen, ) Judges presiding.

JUSTICE MITCHELL delivered the judgment of the court. Presiding Justice Delort and Justice Lyle concurred in the judgment.

ORDER

¶1 Held: We reverse because the trial court violated defendant’s statutory right to a speedy trial and abused its discretion by extending the speedy trial term when the State failed to demonstrate due diligence.

¶2 Defendant Terry Garcia appeals his conviction for driving under the influence of alcohol,

in violation of 625 ILCS 5/11-501(a)(2). Garcia raises the following issue on appeal: did the trial

court abuse its discretion in extending the term under the Speedy Trial Act (725 ILCS 5/103-5

(West 2016)) based upon the State’s representation that a witness, a nurse, had been subpoenaed No. 1-19-2226

when in fact no subpoena had been issued? For the reasons stated below, we conclude that the trial

court abused its discretion, and we reverse.

¶3 BACKGROUND

¶4 On the night of April 13, 2018, Chicago police discovered Terry Garcia at a FedEx

warehouse where he had crashed his car through a fence. Garcia had no serious injuries, but he

sustained a laceration. An ambulance transported him to St. Anthony’s Hospital where he received

medical treatment and a blood draw. Police then brought him to the police station where he

received three citations, including one for DUI.

¶5 On May 7, 2018, Garcia appeared in the circuit court of Cook County. He filed a demand

for speedy trial, thus initiating the 160-day speedy trial term. On June 13, 2018, the court granted

the State a qualified protective order so that it could subpoena Garcia’s medical records from St.

Anthony’s Hospital. Over the next several months, the State responded not ready for trial on four

occasions because it had not yet received Garcia’s records. On each of these occasions, the court

granted the State’s motion for a continuance, and Garcia demanded speedy trial. On the final day

of the 160-day speedy trial term, October 15, 2018, the State moved to extend the term because

two witnesses, a police officer and a nurse, were not present in court. The State also informed the

court that there was an “indication that [the] nurse has been subpoenaed.” In reality, the State had

not yet subpoenaed the nurse. The court granted the extension over Garcia’s objection.

¶6 On the next day, October 16, 2018, the State received Garcia’s medical records from St.

Anthony’s Hospital. The receipt of the records was delayed because the State was delinquent in

paying the hospital’s invoice. On November 5, 2018, the nurse appeared in court for the first time.

-2- No. 1-19-2226

¶7 Garcia moved to dismiss the case arguing that his right to speedy trial had been violated

because he was not tried within the 160-day term and that the trial court abused its discretion in

extending the term. After a hearing, the trial court denied this motion. The court concluded that

the State had demonstrated due diligence despite (1) acknowledging that the State did not subpoena

the nurse until after the court had extended term; (2) knowing that the State secured an extension

of the term by mistakenly representing that the nurse had already been subpoenaed; and (3)

knowing that the State had failed to timely pay a hospital invoice which delayed the receipt of the

medical records until after the expiration of the 160-day term.

¶8 On February 26, 2019, after a bench trial, the trial court found Garcia guilty of driving

under the influence of alcohol. The court sentenced Garcia to 12 months supervision. Garcia filed

a timely posttrial motion, which the court denied. The trial court explained that it did not find any

error in either the decision to grant the 21-day extension or the denial of defense counsel’s motion

to dismiss. This timely appeal followed. Ill. S. Ct. R. 606 (eff. July 1, 2017).

¶9 ANALYSIS

¶ 10 Garcia argues that the trial court abused its discretion by extending the speedy trial term.

He contends that the State failed to demonstrate due diligence, reasoning that the State’s

misrepresentation regarding the nurse’s subpoena did not constitute a sufficient showing of due

diligence. The State argues that it did exhibit due diligence by subpoenaing the hospital on June

13, 2018, and then waiting to receive the necessary records before attempting to secure the nurse’s

presence in court as a witness. Whether a defendant’s right to a speedy trial has been violated is a

legal question reviewed de novo (People v. Pettis, 2017 IL App (4th) 151006, ¶ 17), while a trial

-3- No. 1-19-2226

court’s decision to extend a speedy trial term is reviewed for an abuse of discretion (People v.

Curry, 2020 IL App (2d) 180148, ¶ 39).

¶ 11 The Speedy Trial Act guarantees that upon demand, an accused on bail will receive a trial

within 160 days: “Every person on pretrial release or recognizance shall be tried by the court

having jurisdiction within 160 days from the date the defendant demands trial unless delay is

occasioned by the defendant.” 725 ILCS 5/103-5 (West 2018). The Act also describes the process

by which the court may grant an extension beyond this term:

“If the court determines that the State has exercised without success due diligence to obtain

evidence material to the case and that there are reasonable grounds to believe that such

evidence may be obtained at a later day the court may continue the cause on application of

the State for not more than an additional 60 days.” Id.

To satisfy due diligence, the State must demonstrate that it made continual efforts to obtain

material evidence. People v. Exson, 384 Ill. App. 3d 794, 800 (2008). Therefore, when the State

fails to contact a witness before the trial date due to its own inaction, it has not shown due diligence.

People v. Connors, 2017 IL App (1st) 162440, ¶ 23.

¶ 12 Here, it is undisputed that the basis upon which the State sought an extension of the speedy

trial term was factually false: the State had not subpoenaed the nurse within the 160-day term

despite representing the contrary to the trial court. In fact, at the time the State sought the extension

of the term, it did not even possess the medical records because it had been delinquent in paying

the hospital’s invoice. Nearly a month before the end of the term, on September 19, 2018, the State

received notice that the hospital would not provide the medical records until the State paid its

outstanding invoice. This is significant, because had the State exercised the required diligence at

-4- No. 1-19-2226

that point, it still could have secured the records and subpoenaed the nurse for the October 15,

2018 trial date set for the final day of the term. Against this backdrop, it was an abuse of discretion

Free access — add to your briefcase to read the full text and ask questions with AI

People v. Garcia, 2023 IL App (1st) 192226-U (Ill. Ct. App. 2023).

2023 IL App (1st) 192226-U (People v. Garcia) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

People v. Cruz
2013 IL 113399 (Illinois Supreme Court, 2013)
People v. Caballero
794 N.E.2d 251 (Illinois Supreme Court, 2002)
People v. Exson
896 N.E.2d 844 (Appellate Court of Illinois, 2008)
People v. Denson
2014 IL 116231 (Illinois Supreme Court, 2014)
People v. Pettis
2017 IL App (4th) 151006 (Appellate Court of Illinois, 2017)
People v. Connors
2017 IL App (1st) 162440 (Appellate Court of Illinois, 2017)
People v. Curry
2020 IL App (2d) 180148 (Appellate Court of Illinois, 2020)