People v. Handy

2025 IL App (2d) 240768-U

Opinion

2025 IL App (2d) 240768-U No. 2-24-0768 Order filed December 23, 2025

NOTICE: This order was filed under Supreme Court Rule 23(b) and is not precedent except in the limited circumstances allowed under Rule 23(e)(1). ______________________________________________________________________________

IN THE

APPELLATE COURT OF ILLINOIS

SECOND DISTRICT ______________________________________________________________________________

THE PEOPLE OF THE STATE ) Appeal from the Circuit Court OF ILLINOIS, ) of De Kalb County. ) Plaintiff-Appellee, ) ) v. ) No. 24-MT-984 ) SIMEON N. HANDY, ) Honorable ) Jill K. Konen, Defendant-Appellant. ) Judge, Presiding. ______________________________________________________________________________

JUSTICE BIRKETT delivered the judgment of the court. Justices Hutchinson and Mullen concurred in the judgment.

ORDER

¶1 Held: (1) The trial court had jurisdiction over defendant’s prosecution on two traffic citations. The citations presented justiciable matters, invoking the court’s subject- matter jurisdiction. Also, despite defendant’s purported “special appearance,” the trial court obtained personal jurisdiction over him when he appeared in court. (2) Sufficient evidence supported defendant’s convictions of (a) driving while license revoked, where the police officer observed defendant seated behind the wheel of a vehicle, parked on a highway but with the keys in the ignition, at a time when defendant’s license was revoked and (b) improper display of a license plate, where the license plate on the vehicle had, in fact, been issued to a different vehicle.

¶2 Pro se defendant, Simeon N. Handy, appeals his convictions of driving while license

revoked (625 ILCS 5/6-303(a) (West 2022)) and improper display of a license plate (id. § 3- 2025 IL App (2d) 240768-U

413(b)). Defendant argues that the trial court lacked jurisdiction over this case and that the

evidence was insufficient to support his convictions. We disagree and affirm.

¶3 I. BACKGROUND

¶4 On August 18, 2024, defendant received two citations for traffic offenses. Each citation

was written on an “Illinois Citation and Complaint” form approved by the Illinois Supreme Court.

See 725 ILCS 5/111-3(b) (West 2022) (“[W]hen a citation is issued on a Uniform Traffic Ticket

or Uniform Conservation Ticket (in a form prescribed by the Conference of Chief Circuit Judges

and filed with the Supreme Court), the copy of such Uniform Ticket which is filed with the circuit

court constitutes a complaint to which the defendant may plead, unless he specifically requests

that a verified complaint be filed.” (Emphasis added.)); Ill. S. Ct. R. 552 (eff. Sept. 18, 2023)

(“Uniform Citation and Complaint forms and conservation complaints shall be in forms which

may, from time to time, be approved by the Conference of Chief Circuit Judges and filed with this

court. The uniform forms shall be adapted for use by municipalities.”).

¶5 The first citation was for driving while license revoked, in violation of section 6-303(a) of

the Illinois Vehicle Code (Vehicle Code) (625 ILCS 5/6-303(a) (West 2022)). The citation

indicated that a court appearance was required and that defendant’s appearance was scheduled for

9 a.m. on September 23, 2024.

¶6 The second citation was for improper display of a license plate, in violation of section 3-

413(b) of the Vehicle Code (id. § 3-413(b)). The citation indicated that no court appearance was

required.

¶7 Each citation included the following sworn statement by the arresting officer:

“Under penalties as provided by law for false certification pursuant to section 1-109 of the

Code of Civil Procedure and perjury pursuant to Section 32-2 of the Criminal Code of

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2012, the undersigned certifies that the statements set forth in this instrument are true and

correct.”

¶8 Defendant was pro se throughout the proceedings below. On September 12, 2024,

defendant filed a motion to “[a]dvance court date,” apparently regarding the scheduled September

23, 2024, court date on the first traffic citation. Defendant’s motion indicated that he would appear

on September 20, 2024, at 9 a.m.

¶9 On September 17, 2024, defendant filed a “Motion to strike/Dismiss complaint/case.”

Defendant summarized his grounds for relief: (1) “[f]ailure to present cause of action or crime,”

(2) “[n]o sworn complaint/injury from plaintiff,” and (3) “[l]ack of Jurisdiction to proceed with

judgment.” Elaborating on those grounds, defendant first advised that he was proceeding “by

special appearance, not submig [sic] to the Court’s Jurisdiction.” Defendant asserted that the State

had not alleged “a cause of action or crime,” because defendant was “not accused of violating

anyone’s legal rights” and, thus, there was no “Corpus delicti.” According to defendant, the

“[f]ailure to present the court [with] a case deprive[d] [the] court of jurisdiction.” Thus, because

the State “failed to allege the required elements of a cause of action/crime and there [was] no

Corpus delicti, the court ha[d] no jurisdiction.” Defendant stated that the “foundation for the

[c]ourt’s [j]urisdiction is the purpose of government” itself. Defendant claimed that “standing

represent [sic] a jurisdictional requirement which remains open to review at all stages of the

litigation.”

¶ 10 Defendant filed with his motion a “Notice of Special Appearance to challenge jurisdiction,”

which did not contain written argument.

¶ 11 Defendant and the State appeared in court on September 20, 2024. At that time, the trial

court advised defendant that (1) driving while license revoked was a Class A misdemeanor

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punishable by up to one year in jail and fines up to $2,500, and (2) improper display of a license

plate was a petty traffic offense. The court also admonished defendant of his rights and his duty

to appear on all court dates.

¶ 12 The trial court then noted that defendant had filed his “Motion to strike/Dismiss

complaint/case.” Defendant responded that he had filed “two motions, one for a special

appearance” and “another motion to strike and dismiss.” Defendant declined to offer argument on

his motions. The State also declined to respond to the motions.

¶ 13 The trial court then denied both motions. In particular, the court stated that defendant had

not “alleged anything that would challenge the [court’s] jurisdiction, and the sworn complaint that

[defendant] received was the traffic citation on August 18th of 2024.” Defendant replied that he

did not “understand the nature and causes” against him, and the court explained that it could not

offer him legal advice. In response, defendant said that he was not seeking “legal advice, just legal

intent.” Defendant then asked whether it was “a civil case or a criminal case.” The court responded

that defendant was “charged under the vehicle code of the state of Illinois.” Defendant asked, ”Is

it a criminal offense or is it a civil?” The court clarified, “[I]f it makes you feel better to say it’s a

criminal charge, yes, you’re being charged criminally.” Defendant then asked whether he was

being charged “under common law or admiralty,” to which the court answered that defendant was

not being charged “under either of those,” but “under the statutes of the state of Illinois.” When

defendant asked the court to confirm whether “it’s statutory jurisdiction,” the court explained that

it had “jurisdiction pursuant to the statutes of the state of Illinois.” Defendant responded, “So if

I’m being charged under the statutory jurisdiction, I’ve never heard any record of statutory

adjudication under the constitution, ***.” Defendant asked for the “published rules for

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procedure,” and the court advised defendant to “go to the law library to get that,” because it was

“not [the court’s] job to give [defendant] the statutes.”

¶ 14 Next, the trial court reiterated defendant’s right to an attorney and his option to either set

the case for trial or negotiate with the State for a plea bargain. When defendant asked if he could

negotiate with the State “today,” the court noted that the State did not likely have the police reports

to make an offer. Defendant then requested a “motions hearing” before proceeding to trial, and

the court responded that “no motions” were pending. Defendant asked why his “motions” were

denied, and the court again explained that defendant had failed to “put any allegations to challenge

the jurisdiction.” The court then scheduled the next court date for November 1, 2024.

¶ 15 The court’s orders entered that day reflected that (1) defendant was “[p]resent in person”

in court; (2) defendant’s “motions” were denied; and (3) the court admonished defendant “multiple

times.”

¶ 16 The parties appeared at the next scheduled court date, November 1, 2024. Defendant

announced that he was representing himself and would talk to the State before setting the case for

trial. The State responded that it was pursuing jail time. The parties negotiated off the record, but

no resolution was reached. Next, the State indicated that defendant had filed a motion challenging

the court’s jurisdiction, and the trial court explained that defendant’s motion to that effect had

already been denied. At that time, defendant requested a “motions hearing” before trial because

he planned to file some “new” motions. Defendant asked for further clarification on whether he

was charged with a crime, and the court reiterated that he was being prosecuted under the Vehicle

Code with a petty offense (improper display of a license plate), and a Class A misdemeanor

(driving while license revoked). Defendant then requested a bench trial and signed a jury waiver

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form. In its November 1, 2024, order, the court set the matter for a bench trial on December 9,

2024, and set a cut-off date of November 18, 2024, for any motions in limine.

¶ 17 On November 18, 2024, defendant filed an “OBJECTION BY THE UNDERSIGNED

AFFIANT,” claiming, inter alia, that he was “INVOKING” (1) “SPECIAL APPEARANCE

UNDER DURESS AND THREATS,” (2) “PRIVILEGES AND IMMUNITIES CLAUSE,” and

(3) “THE FULL FAITH AND CREDIT CLAUSE.” Defendant stated that he “[would] not appear

voluntarily and require[d] a valid court order and a verified criminal complaint with evidence

introduced by [the State] showing an injury in fact (‘corpus delicti’) caused by [defendant].”

(Emphasis in original.) Later in the “OBJECTION,” defendant listed “QUESTIONS AND

EVIDENCE THIS COURT MUST PRODUCE WITHIN FOURTEEN (14) DAYS AFTER

RECEIPT OF THIS NOTICE OR THE PROCEEDINGS SHALL BE DISMISSED FOR

DEFAULT[.]” One question was: “Where is the verified complaint sworn under threat of perjury

from the [State]?” We note that the record contains no proof of service for the “OBJECTION.”

¶ 18 The parties appeared for a bench trial on December 9, 2024. Defendant confirmed that he

wished to represent himself. Before the trial began, the State advised the trial court that defendant

had filed “some sort of motion” on November 18, 2024. The court acknowledged that “an

objection [was] filed on the 18th.” The following colloquy ensued:

“MS. DARSIE [(ASSISTANT STATE’S ATTORNEY)]: And the State never

received notice of that, Your Honor. I just became aware of it when I was reviewing the

electronic file today.

THE COURT: Oh, okay. I do not see any relief requested, I don’t see—it just is an

objection filed by the defendant.

MS. DARSIE: All right. So then—

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THE COURT: So I’m going to just overrule that objection and we’re going to

proceed with trial.

MS. DARSIE: Thank you, [Y]our Honor. At this time [the] State would waive

opening statement.

THE COURT: All right. Mr. Handy, would you like to make an opening statement?

DEFENDANT: This is a sworn affidavit, and by law this must be ruled upon,

discussed. I don’t even think anyone read it. So it’s about eight pages, it’s a sworn

affidavit.

THE COURT: Well, did you give notice to the State of this? When you filed this,

did you give—

DEFENDANT: Well, when I—when I called the lady, she said they do that

automatically, so—

THE COURT: That’s not correct. Anything that you file, you’re obligated—

DEFENDANT: Well, that’s what I was told.

THE COURT: —to provide a copy of it to the State’s Attorney’s Office.

DEFENDANT: She said she put a notice to the State’s Attorneys [sic] right by the

door, so that’s the only reason why I filed it electronically. I filed a few things, I’ve never

had this problem. She said she put a copy in the State’s Attorney’s door.

THE COURT: Okay, all right. So—

DEFENDANT: So—

THE COURT: —anything else you want to say?

DEFENDANT: Yeah. I have a sworn affidavit, so by law—

THE COURT: Okay, well—

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DEFENDANT: —we’re supposed to go over this.

THE COURT: —I’ve already ruled—I viewed your objection—

DEFENDANT: We didn’t even go over it. We didn’t even go over it. We didn’t

even go over it. We have to go over it by law.

THE COURT: We don’t have to go over it. That is your—I read your objection by

the undersigned affiant, and we are going to proceed as scheduled today, so that’s what

we’re going to go forward with. ***.”

¶ 19 The State waived its opening statement. Its only witness was Deputy Timothy Smith, who

testified as follows. Smith had served as a patrol deputy for 16 years. On August 18, 2024, around

11:30 a.m., dispatch advised Smith of a custody dispute at a residence on South 8th Street in the

Village of Kirkland. According to Smith, 8th Street was a “public roadway.” When Smith arrived

at the address, he saw a gold GMC Acadia parked on the road in front of the residence. Smith “ran

the license plate” and learned that the registration had been issued for a vehicle that did not match

the Acadia. That discrepancy, Smith explained, constituted the offense of improper display of a

license plate, in violation of the Vehicle Code.

¶ 20 Smith approached the vehicle, which was occupied by just “one gentleman,” who was later

identified as defendant. Defendant was sitting “behind the wheel.” When Smith was asked if

“there [were] keys in the ignition of the vehicle,” he replied, “They were there with the vehicle,

yes.” Smith asked defendant why he was parked outside the residence, and defendant responded

that he was picking up a friend’s child. Smith then asked defendant his name, and defendant

answered, “Derek Pryor.” After Smith was unable to confirm defendant’s identity as Derek Pryor,

he asked defendant for his date of birth. Defendant refused to provide that information. At that

point, Smith asked defendant to exit the vehicle, which he did. When defendant opened the car

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door, Smith heard a “dinging sound.” Smith explained that such a sound “[t]ypically” means that

the vehicle’s keys are in the ignition. A backup officer stood by as Smith questioned defendant

outside the vehicle. Smith then spoke to the complainant of the custody dispute. The complainant,

defendant’s ex-wife, identified defendant as Simeon Handy.

¶ 21 Smith was wearing a body camera that day and had reviewed the video footage of his

encounter with defendant. The video footage was admitted into evidence as State’s exhibit No. 1,

without objection. The first five to six minutes of the video footage were played for the court and

were consistent with Smith’s testimony. When Smith approached the Acadia, defendant was

sitting behind the steering wheel with the driver’s window slightly down. Defendant stated that

his name was Derek Pryor and that he was there to pick up a friend’s son. When defendant refused

to state his date of birth, Smith ordered defendant to exit the vehicle, and defendant complied.

When defendant did so, a dinging sound could be heard inside the vehicle. Defendant’s ex-wife

then identified defendant as Simeon Handy, her ex-husband. Smith’s backup officer noted that

defendant had five outstanding warrants.

¶ 22 Smith resumed testifying and stated that, after defendant’s identity was confirmed, he was

handcuffed and placed under arrest. A search of defendant’s vehicle revealed a State of Illinois

identification card, which was admitted as State’s exhibit No. 2, without objection. The card bore

the name Simeon Handy and a Naperville address. Smith testified that defendant’s ex-wife

confirmed that defendant did not live with her at the Kirkland residence.

¶ 23 Smith testified that the presence of the keys in the ignition indicated that defendant had

been in “in actual physical control of the vehicle.” While at the scene, Smith checked defendant’s

name with the secretary of state and learned that his driving privileges were revoked at that time.

The State then offered State’s exhibit No. 3, which was the certified driving abstract from the

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secretary of state showing that defendant’s driving privileges had been revoked. The exhibit was

admitted into evidence without objection.

¶ 24 Smith testified that defendant was cited for driving while license revoked and improper

display of a license plate. Smith explained that he issued the driving-after-revocation citation

because, in addition to defendant’s then-revoked license, defendant was sitting inside the vehicle;

the vehicle was not registered to the address in Kirkland, but to a different city and county; and no

one else was present with defendant in the vehicle. Smith issued the license-plate citation because

the license plate on the gold GMC Acadia “came back to a separate vehicle.”

¶ 25 Defendant cross-examined Smith. When defendant asked whether he had put the key in

the ignition to roll down the window, Smith answered, “I can’t recall.” Smith admitted that he did

not perform a “traffic stop” on the gold GMC Acadia. Next, defendant commented that the vehicle

“was in park,” but he failed to pose a question to Smith. The court subsequently sustained

numerous objections by the State on the basis that defendant’s questions either sought legal

conclusions or lacked relevancy.

¶ 26 The State rested. When the trial court asked defendant how he wanted to proceed, the

conversation turned again to the question of jurisdiction. Defendant said it was the trial court’s

“duty to explain to [him] the jurisdiction,” and the court reiterated that it had no duty to give

defendant legal advice. The court then asked defendant whether he wanted to make a motion or

testify. Defendant said that he was “definitely going to make a motion.” The court observed that

defendant was “trying to *** read [his previously denied] [‘OBJECTION’],” and the court would

not permit it. Defendant then made an oral motion to dismiss the case, which the court denied.

When defendant asked why his oral motion was denied, the court stated that it had read defendant’s

[“OBJECTION”] and was “overruling” it. When defendant asked the “grounds” for that ruling,

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the court answered, “On the grounds that the State has a right to prosecute you under the Vehicle

Code, the [c]ourt does have jurisdiction, and we’re set for trial today. We’re in the middle of trial.”

¶ 27 Next, defendant asked if there was a “sworn complaint from an injured party or an injured

party present.” The court responded that defendant was “issued two citations,” each of which had

a sworn statement by the officer. After being asked multiple times whether he wished to testify,

defendant said, “I don’t need to testify.” The court explained that, because defendant was not

presenting any evidence, “the trial [was] over.” Defendant then made another oral motion,

claiming that the parties were in the “wrong courtroom.” The court denied that motion as well.

After repeated questioning by the court, defendant reiterated that he did not wish to testify.

¶ 28 The State delivered its closing argument. Defendant’s closing argument began:

“Okay. So by all of this assumption or presumption or whatever the case may be,

by the Supreme Court law, to be found guilty of a crime you must have a sworn complaint

from the injured party or injured party present which was never presented, so therefore,

you do not have jurisdiction to move. ***.”

Defendant further argued that the State’s failure “to meet the constitutional minimum standard of

an injury in fact” was a “cause for dismissal for lack of subject-matter jurisdiction to prosecute.”

¶ 29 The trial court found defendant guilty of both driving while license revoked and improper

display of a license plate.

¶ 30 A sentencing hearing immediately followed. The State asked for a jail sentence based on

defendant’s 20-year history of license suspensions and revocations. The trial court imposed a

sentence of 24 months of conditional discharge, 10 days in jail, and $825 in fines and assessments.

¶ 31 This timely appeal followed.

¶ 32 II. ANALYSIS

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¶ 33 At issue in this appeal is whether the trial court possessed subject-matter jurisdiction over

defendant’s case and personal jurisdiction over defendant himself. Also at issue is whether there

was sufficient evidence to find defendant guilty beyond a reasonable doubt of both traffic offenses.

¶ 34 A. Jurisdiction

¶ 35 Defendant first argues that the trial court lacked jurisdiction to hear his case, rendering its

judgments void. According to defendant, when jurisdiction is “formally challenged, the burden

shifts to the court to establish, on the record, that it has both subject matter and personal jurisdiction

before proceeding.” In defendant’s mind, the trial court “failed to address or establish its

jurisdiction,” and, by “continuing proceedings without addressing [defendant’s] jurisdictional

challenge,” the court “acted in excess of its authority and violated [defendant’s] constitutional

rights under the Fourteenth Amendment to the U.S. Constitution.” We reject defendant’s

contentions.

¶ 36 “In a general sense, ‘jurisdiction’ refers to the ‘right or power to interpret and apply the

law,’ or to a court’s ‘sphere of authority or control.’ ” In re M.W., 232 Ill. 2d 408, 414 (2009)

(quoting Webster’s II New Collegiate Dictionary 601 (1st ed. 1999)). “In a technical, legal sense,

however, jurisdiction is composed of two distinct elements: subject matter jurisdiction and

personal jurisdiction.” Id. If a court lacks either jurisdictional element, “any order entered in the

matter is void ab initio and, thus, may be attacked at any time.” Id. The issue of whether a trial

court had subject-matter jurisdiction presents a question of law, which we review de novo.

Millennium Park Joint Venture, LLC v. Houlihan, 241 Ill. 2d 281, 294 (2010). Likewise, we

review de novo whether the trial court obtained personal jurisdiction over the defendant. People

v. Matthews, 2016 IL 118114, ¶ 9.

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¶ 37 Subject-matter jurisdiction “refers to the power of a court to hear and determine cases of

the general class to which the proceeding in question belongs.” Belleville Toyota, Inc. v. Toyota

Motor Sales, U.S.A., Inc., 199 Ill. 2d 325, 334 (2002). “With the exception of the circuit court’s

power to review administrative action, which is conferred by statute”—and is not at issue here—

“a circuit court’s subject matter jurisdiction is conferred entirely by our state constitution.” Id.

(citing Ill. Const. 1970, art. VI, § 9). “[S]ubject matter jurisdiction *** is invoked by the filing of

a petition or complaint alleging the existence of a justiciable matter.” M.W., 232 Ill. 2d at 426.

“[A] ‘justiciable matter’ is a controversy appropriate for review by the court, in that it is definite

and concrete, as opposed to hypothetical or moot, touching upon the legal relations of parties

having adverse legal interests.” Belleville Toyota, 199 Ill. 2d at 335. “[E]ven a defectively stated

claim is sufficient to invoke the court’s subject matter jurisdiction, as ‘[s]ubject matter jurisdiction

does not depend upon the legal sufficiency of the pleadings.’ ” In re Luis R., 239 Ill. 2d 295, 301

(2010) (quoting Belleville Toyota, 199 Ill. 2d at 340). Indeed, the only consideration is whether

the alleged claim falls within the general class of cases that the court has the inherent power to

hear and determine. Id. If it does, then subject-matter jurisdiction is present. Id. Subject-matter

jurisdiction cannot be waived or forfeited. Belleville Toyota, 199 Ill. 2d at 333.

¶ 38 Defendant’s argument that the trial court lacked subject-matter jurisdiction over his traffic

offenses charged under the Vehicle Code lacks merit. Instructive here is People v. Sellers, 2015

IL App (4th) 140604-U, ¶¶ 5, 17, 1 where the defendant argued that the trial court lacked subject-

matter jurisdiction over his prosecution for two traffic offenses. The defendant was charged “by

1 Even before the 2021 amendment to Illinois Supreme Court Rule 23(e) (eff. Jan 1. 2021) allowing

parties to cite nonprecedential decisions for persuasive purposes, courts could rely on the reasoning of

nonprecedential decisions. See People v. Ingram, 2020 IL App (2d) 180353, ¶ 21 n.1.

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way of two traffic tickets” with driving with an alcohol concentration of 0.08 or more (625 ILCS

5/11-501(a)(1) (West 2012)) and driving under the influence of alcohol (id. § 11-501(a)(2))—both

in violation of the Vehicle Code. Sellers, 2015 IL App (4th) 140604-U, ¶ 5. Citing supreme court

precedent on subject-matter jurisdiction, the Sellers court determined that the traffic citations

presented “matters that [were] appropriate for review by the trial court,” and, therefore, “the court

had subject-matter jurisdiction to decide whether [the] defendant committed the charged offenses.”

Id. ¶¶ 18-19 (citing Belleville Toyota, 199 Ill. 2d at 334; Luis R., 239 Ill. 2d at 301).

¶ 39 Here, as in Sellers, the trial court clearly had subject-matter jurisdiction to determine

whether defendant committed the two charged traffic offenses, namely driving while license

revoked and improper display of a license plate. Subject-matter jurisdiction was conferred by the

Illinois Constitution because each citation charging an offense presented a “definite and concrete”

controversy “touching upon the legal relations of parties having adverse legal interests.” See

Belleville Toyota, 199 Ill. 2d at 335; Sellers, 2015 IL App (4th) 140604-U, ¶¶ 18-19; People v.

Stroud, 2020 IL App (3d) 190064, ¶ 8 (“Subject matter jurisdiction was conferred by the Illinois

Constitution because a prosecution for driving without a valid driver’s license is a justiciable

matter.”). Thus, the trial court incontestably had subject-matter jurisdiction over the prosecution

of the traffic charges.

¶ 40 Defendant emphasizes that “there is no sworn and verified complaint on record from the

[State].” Specifically, defendant argues that a “verified complaint is required to invoke the trial

court’s jurisdiction in a criminal or traffic matter,” and an “unsworn complaint is insufficient to

invoke jurisdiction.” According to defendant, without “a [sworn] complaint on file, there is no

lawful accuser, no valid initiation of prosecution, and no proper subject matter jurisdiction.”

Defendant concludes that, because “there is no sworn and verified complaint on record from the

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plaintiff, the proceedings were improperly initiated, depriving the court of jurisdiction and

[defendant] of due process.”

¶ 41 Defendant’s argument implicates the difference between a sworn citation and a verified

complaint. Both citations here contained a sworn statement by the officer, in the following form:

“Under penalties as provided by law for false certification pursuant to section 1-109 of the

Code of Civil Procedure and perjury pursuant to Section 32-2 of the Criminal Code of

2012, the undersigned certifies that the statements set forth in this instrument are true and

Section 111-3(b) of the Code of Criminal Procedure of 1963 (725 ILCS 5/111-3(b) (West 2022))

provides that, if a citation is issued on a “Uniform Traffic Ticket” form, as both citations here

were, “the copy of such Uniform Ticket which is filed with the circuit court constitutes a complaint

to which the defendant may plead, unless he specifically requests that a verified complaint be

filed.” (Emphasis added.) However, a complaint need not be verified to provide a basis for

subject-matter jurisdiction. People v. Pankey, 94 Ill. 2d 12, 17 (1983); People v. Bradford, 62 Ill.

2d 21, 22 (1975). See Luis R., 239 Ill. 2d at 301 (subject-matter jurisdiction does not depend on

the legal sufficiency of the pleading). The citations here, though not in the form of formal, verified

complaints, presented justiciable matters and thus were sufficient to invoke the trial court’s

subject-matter jurisdiction.

¶ 42 Further, defendant is mistaken that the trial court failed to address his “jurisdictional

challenge.” On the trial date and the two prior hearings in this case, the court addressed

defendant’s repeated oral and written arguments challenging its jurisdiction. As explained, the

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trial court was correct to deny those challenges, as both traffic offenses were justiciable matters

appropriate for review by the court. 2

¶ 43 In addition, we note that none of the authorities that defendant cites support his position on

subject-matter jurisdiction. For instance, contrary to defendant’s assertion that People v. Pahl,

124 Ill. App. 2d 177 (1970), “held that an unsworn complaint is insufficient to invoke jurisdiction,”

the Pahl case contains no discussion of jurisdiction. Similarly, the three other cases defendant

references are either cited incorrectly or do not contain the propositions of law for which he cites

them. For the foregoing reasons, we hold that the trial court had subject-matter jurisdiction over

the prosecution of the charged traffic offenses, despite the absence of a verified complaint.

¶ 44 Also, to the extent that defendant makes a nonjurisdictional due process argument that the

trial court erred in denying his request for a verified complaint, that argument fails as well.

Defendant’s “OBJECTION” stated that he “[would] not appear voluntarily and require[d] a valid

court order and a verified criminal complaint with evidence introduced by [the State] showing an

injury in fact (‘corpus delicti’) caused by [defendant].” Later in the filing, defendant declared

rather boldly that the matter would be dismissed within 14 days if the trial court did not answer

his question, “Where is the verified complaint sworn under threat of perjury from the [State]?”

The foregoing statements read more like threats than “specific[ ] request[s]” (725 ILCS 5/111-3(b)

2 The trial court told defendant that it had jurisdiction under the “statutes” of Illinois. However,

“circuit court jurisdiction is conferred by the constitution and not by statute, except in the administrative

review context” (Cedzidlo v. Marriott International, Inc., 404 Ill. App. 3d 578, 582 (2010)), which is not

the context here. Nonetheless, because our review is de novo, we may affirm the finding of subject-matter

jurisdiction for different reasons than the trial court cited. See Moore v. Pendavinji, 2024 IL App (1st)

231305, ¶ 20.

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(West 2022)) for a verified complaint. In any event, the record contains no proof of service of the

“OBJECTION.” Three weeks after defendant filed the “OBJECTION,” the case was called for

trial. The State said that it had only that day become aware of the “OBJECTION” when it was

reviewing the electronic case file. Although defendant told the trial court that he had filed his

written objection electronically and was advised that the State would receive notice, the State

denied receiving proper notice, and the trial court “overrul[ed]” the “OBJECTION” before

proceeding to trial. The record is clear that defendant failed to properly serve the State with the

“OBJECTION.” As the State notes, defendant cannot challenge the trial court’s order based on

his own failure to properly serve the State. See People v. Smith, 2017 IL App (3d) 150265, ¶ 17.

Defendant has forfeited any objection to the State proceeding without a verified complaint. See

Pankey, 94 Ill. 2d at 17. Alternatively, we find that the citations, which used the “Illinois Citation

and Complaint” form approved by the Illinois Supreme Court, gave defendant adequate notice of

the charges. See Sellers, 2015 IL App (4th) 140604-U, ¶ 20 (traffic tickets using the “uniform

traffic citation” form “sufficiently set forth the offenses upon which [the] defendant was being

charged”); People v. Tammen, 40 Ill. 2d 76, 78-79 (1968) (“Inasmuch as the Uniform Traffic

Ticket is only used for misdemeanors, is written by an arresting officer rather than a State’s

Attorney and is generally written at the time the offense is committed, we believe that naming the

offense and citing it is sufficient and will generally be understood by the person charged.”).

Despite his references to “due process,” defendant fails to develop any argument that the citations

did not comport with that constitutional norm. See Ill. S. Ct. R. 341(h)(7) (eff. Oct. 1, 2020)

(failure to support an argument with reasoned analysis and citation to authority results in

forfeiture).

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¶ 45 Next, we consider whether the trial court possessed personal jurisdiction over defendant.

Unlike subject-matter jurisdiction, which, as noted, is invoked by the filing of a petition or

complaint alleging the existence of a justiciable matter, personal jurisdiction is “ ‘derived from the

actions of the person sought to be bound.’ ” M.W., 232 Ill. 2d at 426 (quoting Meldoc Properties

v. Prezell, 158 Ill. App. 3d 212, 216 (1987)). A defendant “may consent to personal jurisdiction

by his appearance, or he may have personal jurisdiction imposed upon him by effective service of

summons.” Id. Once the trial court acquires personal jurisdiction over a party, it has the power to

impose personal obligations on him, and that jurisdiction continues until all issues of fact and law

in the case are determined. Id.

¶ 46 The State points to Stroud, where the defendant was charged with driving without a valid

license (625 ILCS 5/6-101 (West 2018)). Stroud, 2020 IL App (3d) 190064, ¶ 3. The defendant

challenged the trial court’s jurisdiction, and the court explained that the trial court “had personal

jurisdiction over [the] defendant because he appeared in court after the traffic ticket complaint was

filed.” Id. ¶ 8. In so holding, the Stroud court relied on People v. Kleiss, 90 Ill. App. 3d 53, 55

(1980), which stated that jurisdiction over the person of the accused is acquired when he appears

personally before the court. Stroud, 2020 IL App (3d) 190064, ¶ 8.

¶ 47 As in Stroud and Kleiss, the trial court in this case had personal jurisdiction over defendant

once he appeared in court in response to the traffic citations. Indeed, it was defendant who filed a

motion to “[a]dvance court date” from September 23, 2024, to September 20, 2024, and he

appeared in court on the latter date. He thereafter appeared on November 1 and December 9, 2024.

Although defendant purported to file a “special appearance” on September 17, 2024, to preserve a

jurisdictional challenge, his physical presence in court three days later indisputably conferred

personal jurisdiction over him. See People v. Bliss, 44 Ill. 2d 363, 369 (1970) (even an illegal

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arrest does not preclude the trial court from obtaining personal jurisdiction over the defendant in a

criminal case).

¶ 48 Finally, as to the trial court’s treatment of jurisdiction generally, we note defendant’s

comment that, when jurisdiction is “formally challenged, the burden shifts to the court to establish,

on the record, that it has both subject matter and personal jurisdiction before proceeding.” As we

have explained, the trial court addressed defendant’s jurisdictional objections. The record clearly

shows that the trial court had both subject-matter jurisdiction over the proceeding and personal

jurisdiction over defendant.

¶ 49 B. Sufficiency of the Evidence

¶ 50 Last, we address defendant’s argument that he was not found guilty of the traffic offenses

beyond a reasonable doubt. The due process clause of the fourteenth amendment to the United

States Constitution requires that a defendant may not be convicted in a state court except upon

proof beyond a reasonable doubt of every fact necessary to constitute the crime with which the

defendant is charged. People v. Wheeler, 226 Ill. 2d 92, 114 (2007). When reviewing a challenge

to the sufficiency of the evidence, we consider whether, viewing the evidence in the light most

favorable to the State, any rational trier of fact could have found the essential elements of the crime

beyond a reasonable doubt. Id. “When considering a challenge to a criminal conviction based

upon the sufficiency of the evidence, our function is not to retry the defendant.” People v.

Sutherland, 223 Ill. 2d 187, 242 (2006). In other words, when reviewing the evidence, we will not

substitute our judgment for that of the trier of fact. Id. Rather, “[t]he weight to be given witnesses’

testimony, the witnesses’ credibility, and the reasonable inferences to be drawn from the evidence,

are all the responsibility of the fact finder.” People v. Milka, 211 Ill. 2d 150, 178 (2004).

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¶ 51 According to defendant, “the record is devoid of sufficient evidence showing that a legally

cognizable crime occurred,” and “the prosecution failed to present evidence sufficient to establish

that an actual crime occurred.” “There is either a complete absence of an essential element (such

as intent, actus reus, or jurisdiction), or the acts proven do not amount to a crime under the law.”

¶ 52 Defendant fails to cite the record or incorporate the trial evidence into his argument. Our

supreme court rules provide that contentions in appellate briefs must be supported by citations to

the record and reasoned analysis, and contentions not so developed are forfeited. See Ill. S. Ct. R.

341(h)(7) (eff. Oct. 1, 2020). Defendant’s pro se status does not excuse him from compliance with

these briefing requirements. See Litwin v. County of La Salle, 2021 IL App (3d) 200410, ¶ 3.

Although we would be justified in finding defendant’s argument forfeited, we will briefly address

the merits.

¶ 53 As to the charge of driving while license revoked, section 6-303(a) of the Vehicle Code

(625 ILCS 5/6-303(a) (West 2022)) provides that

“any person who drives or is in actual physical control of a motor vehicle on any highway

of this State at a time when such person’s driver’s license, permit, or privilege to do so or

the privilege to obtain a driver’s license or permit is revoked or suspended as provided by

this Code *** shall be guilty of a Class A misdemeanor.”

¶ 54 At trial, the State established all elements of the offense through Smith’s testimony, his

body camera video, and the documentary evidence. Smith testified that he was dispatched to a

residence on South 8th Street in the Village of Kirkland and observed a gold GMC Acadia parked

on the street in front of the residence. Defendant was sitting behind the wheel of the Acadia. When

Smith was asked if “there [were] keys in the ignition of the vehicle,” he answered, “They were

there with the vehicle, yes.” When defendant exited the Acadia, there was a “dinging sound,”

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which, Smith explained, “[t]ypically” means that the keys are in the vehicle’s ignition. This

evidence established that defendant was in “actual physical control” of the Acadia. See City of

Naperville v. Watson, 175 Ill. 2d 399, 402 (1997) (“A person need not drive to be in actual physical

control of a vehicle, nor is the person’s intent to put the car in motion relevant to the determination

of actual physical control. [Citation.] The issue of actual physical control is determined on a case-

by-case basis giving consideration to factors such as whether the motorist is positioned in the

driver’s seat of the vehicle, has possession of the ignition key[,] and has the physical capability of

starting the engine and moving the vehicle.”). Also, based on Smith’s testimony that South 8th

Street was a “public roadway,” the State proved that defendant had actual physical control of the

Acadia while it was on a “highway.” See 625 ILCS 5/1-126 (West 2022) (defining “highway” as

“[t]he entire width between the boundary lines of every way publicly maintained when any part

thereof is open to the use of the public for purposes of vehicular travel or located on public school

property[ ]”). Moreover, defendant’s identification card showed a Naperville address, and

defendant’s ex-wife confirmed that defendant did not live with her at the Kirkland residence. Thus,

as the State points out, it was reasonably inferable that, on the day of his arrest, defendant drove

his vehicle on highways to arrive in Kirkland. See People v. Cunningham, 212 Ill. 2d 274, 280

(2004) (the reviewing court must allow all reasonable inferences from the record in favor of the

State). Finally, the State introduced a certified driving abstract from the secretary of state showing

that, on the date defendant was arrested, his driving privileges had been revoked. See People v.

Younge, 83 Ill. App. 3d 305, 309 (1980) (the legislature has mandated that the secretary of state

shall maintain appropriate records of all licenses and permits refused, canceled, revoked, or

suspended; and a certified copy from the secretary, maintained pursuant to statutory mandate,

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under his signature and seal, is admissible into evidence). Thus, the State proved defendant guilty

beyond a reasonable doubt of driving while license revoked.

¶ 55 Likewise, the State proved defendant guilty beyond a reasonable doubt of improper display

of a license plate. Section 3-413(b) of the Vehicle Code (625 ILCS 5/3-413(b) (West 2022)) states

that “every registration plate or digital registration plate shall at all times be securely fastened in a

horizontal position to the vehicle for which it is issued ***.” (Emphasis added.)

¶ 56 Smith testified that, when he encountered defendant parked near the Kirkland residence,

defendant was positioned behind the steering wheel of a gold GMC Acadia vehicle. When Smith

ran the license plate of the Acadia, he learned that the registration had been issued for a vehicle

that did not match the Acadia. Smith’s testimony was sufficient to prove the elements of the

offense.

¶ 57 III. CONCLUSION

¶ 58 For the reasons stated, we affirm the judgment of the circuit court of De Kalb County.

¶ 59 Affirmed.

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