People v. Hermansen

CourtAppellate Court of Illinois
DecidedJuly 1, 2026
Docket5-25-0038
StatusUnpublished

This text of People v. Hermansen (People v. Hermansen) 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. Hermansen, (Ill. Ct. App. 2026).

Opinion

NOTICE 2026 IL App (5th) 250038-U NOTICE Decision filed 07/01/26. The This order was filed under text of this decision may be NO. 5-25-0038 Supreme Court Rule 23 and is changed or corrected prior to not precedent except in the the filing of a Petition for IN THE limited circumstances allowed Rehearing or the disposition of under Rule 23(e)(1). the same. APPELLATE COURT OF ILLINOIS

FIFTH DISTRICT ______________________________________________________________________________

THE PEOPLE OF THE STATE OF ILLINOIS, ) Appeal from the ) Circuit Court of Plaintiff-Appellee, ) Douglas County. ) v. ) No. 24-CM-29 ) FRANK A. HERMANSEN, ) Honorable ) Katherine Demira Watson, Defendant-Appellant. ) Judge, presiding. ______________________________________________________________________________

JUSTICE HACKETT delivered the judgment of the court. Justices Barberis and Boie concurred in the judgment.

ORDER

¶1 Held: The defendant’s conviction for resisting or obstructing a peace officer is reversed because the indictment was fatally defective.

¶2 Following a jury trial, the defendant, Frank A. Hermansen, was convicted of resisting or

obstructing a peace officer (720 ILCS 5/31-1 (West 2024)). Thereafter, the circuit court of Douglas

County sentenced him to 12 months’ probation. The defendant appeals, arguing that (1) his

conviction should be reversed due to defects in the State’s charging instrument; (2) the trial court

committed plain error by failing to instruct the jury as to the law in effect at the time of the offense,

or alternatively, defense counsel rendered ineffective assistance for not raising the issue in the trial

court; (3) the trial court abused its discretion in denying the jury’s request for definitions of

1 “resisting” and “obstructing”; and (4) the cumulative effect of the errors deprived the defendant of

a fair trial. For the reasons that follow, we reverse the circuit court’s judgment.

¶3 I. BACKGROUND

¶4 On April 24, 2024, the State charged the defendant with resisting or obstructing a peace

officer (id.). Specifically, the information stated as follows:

“That on April 23, 2024, in Douglas County, [the defendant], committed the offense

of RESISTING OR OBSTRUCTING A PEACE OFFICER, in that said defendant

knowingly resisted or obstructed the performance of Charles Abarbanel, Arcola Police

officer, of an authorized act within his official capacity, knowing Charles Abarbanel to be

a peace officer engaged in the execution of his official duties, in that said defendant refused

to obey the officer’s verbal commands, pulled away from the officer, and continued to

actively physically resist the officer’s attempts to control the defendant, in violation of 720

ILCS 5/31-1.”

The defendant did not file a pretrial motion challenging the information or a bill of particulars.

¶5 On November 12, 2024, the jury trial was held, and the following evidence was presented.

Charles Abarbanel, a police officer at the Arcola Police Department, testified that on April 23,

2024, at 1:27 a.m., he observed a Chrysler van turning into and out of a drive that led to a field and

then continuing in its original direction of travel. When Officer Abarbanel ran the license plate, he

learned that the defendant was the registered owner, and a warrant had been issued for the

defendant’s arrest. Officer Abarbanel followed the van into a gas station parking lot. Officer

Abarbanel approached the defendant and asked for identification, but the defendant did not provide

any identification. Instead, the defendant told Officer Abarbanel to refer to the name on the

2 defendant’s shirt. Officer Abarbanel initially did not recognize the defendant, but after speaking

with the defendant, Officer Abarbanel recognized the defendant from a prior contact.

¶6 During the course of the traffic stop, Officer Abarbanel attempted to have the defendant

exit the vehicle, so that Officer Abarbanel could place the defendant under arrest on the warrant.

However, the defendant did not comply with Officer Abarbanel’s multiple requests to exit the

vehicle. At some point during the encounter, Officer Abarbanel opened the driver’s side door and

attempted to remove the defendant from the vehicle by grabbing the defendant’s left wrist. Officer

Abarbanel attempted to also grab the defendant’s left forearm, but the defendant “yanked his left

arm back in a very aggressive manner.” Officer Abarbanel then radioed the officers who were

already on their way to the scene to let them know that the defendant was not exiting the vehicle

and that he needed a faster response.

¶7 Eventually, two other officers arrived, and with their assistance, the defendant was placed

into custody. After the defendant exited the vehicle, he turned his back to Officer Abarbanel and

attempted to reach inside the vehicle for something. Officer Abarbanel did not know what the

defendant was reaching for at the time. Officer Abarbanel then pulled the defendant away from

the vehicle. Officer Abarbanel testified that the traffic stop was prolonged because the defendant

repeatedly refused to follow Officer Abarbanel’s verbal commands. The encounter with the

defendant was recorded by the dash-mounted camera in Officer Abarbanel’s squad car, and the

recording was played for the jury.

¶8 In the video, Officer Abarbanel approached the defendant’s van, and the defendant asked

whether he had committed any crime and accused Officer Abarbanel of being nosy and following

him. Officer Abarbanel responded that he was conducting a Terry stop (Terry v. Ohio, 392 U.S. 1

(1968)) and asked whether the defendant knew what a Terry stop was. The defendant said that he

3 did not care what a Terry stop was and that he was just lost and had made a wrong turn. Officer

Abarbanel asked for the defendant’s driver’s license, and the defendant refused to give his license

to Officer Abarbanel. Officer Abarbanel told the defendant that he was required to provide his

driver’s license, and the defendant responded that he did not care and to arrest him and again asked

whether he had committed a crime. When Officer Abarbanel asked the defendant whether he was

Frank, the defendant responded by asking if Officer Abarbanel was stupid and noting that his name

was on his shirt. Officer Abarbanel then returned to his squad car and confirmed that there was a

warrant for the defendant’s arrest. Officer Abarbanel also informed dispatch that the defendant

was refusing to give any identification, and he would be surprised if the defendant exited the

vehicle.

¶9 Officer Abarbanel then returned to the defendant’s vehicle and told the defendant to get

out of the vehicle because of the warrant. The defendant responded that he did not believe that

there was a warrant, but he needed to call his wife because his son was in the backseat. The

defendant again started questioning why he was pulled over, and Officer Abarbanel told him to

get out of the vehicle and that he could call his wife once he was out of the car. The defendant

asked what Officer Abarbanel was going to do when he got out of the car. Officer Abarbanel

responded that he was just going to put the defendant in handcuffs. The defendant again noted that

his son was in the vehicle. Officer Abarbanel responded that he did not want to handcuff the

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Cite This Page — Counsel Stack

Bluebook (online)
People v. Hermansen, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-hermansen-illappct-2026.