People v. Hyde

2025 IL App (2d) 240312-U
CourtAppellate Court of Illinois
DecidedJune 25, 2025
Docket2-24-0312
StatusUnpublished

This text of 2025 IL App (2d) 240312-U (People v. Hyde) 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. Hyde, 2025 IL App (2d) 240312-U (Ill. Ct. App. 2025).

Opinion

2025 IL App (2d) 240312-U No. 2-24-0312 Order filed June 25, 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 Kane County. ) Plaintiff-Appellee, ) ) v. ) No. 22-CF-218 ) TYLOR HYDE, ) Honorable ) Julia A. Yetter, Defendant-Appellant. ) Judge, Presiding. ______________________________________________________________________________

JUSTICE MULLEN delivered the judgment of the court. Presiding Justice Kennedy and Justice Hutchinson concurred in the judgment.

ORDER

¶1 Held: We affirm defendant’s conviction of aggravated battery to a peace officer based on circumstantial evidence that, when defendant pushed himself back from a wall against which he had been pressed by police officers attempting to restrain him, defendant was aware from the force of his act that it was practically certain to cause great bodily harm to the officer behind him, who, in fact, suffered a pectoral tendon tear.

¶2 Defendant, Tylor Hyde, appeals from his conviction, following a bench trial, of aggravated

battery to a peace officer (720 ILCS 5/12-3.05(a)(3)(i) (West 2020)). He contends that the State

failed to prove him guilty beyond a reasonable doubt, because it failed to prove that he knowingly

caused great bodily harm to the peace officer. We affirm. 2025 IL App (2d) 240312-U

¶3 I. BACKGROUND

¶4 On May 10, 2022, defendant was indicted on three counts of aggravated battery to a peace

officer (id. §§ 12-3.05(a)(3)(i), (d)(4)(i) (West 2020)), one count of aggravated battery (id. § 12-

3.05(a)(1)), one count of aggravated assault of a peace officer (id. § 12-2(b)(4.1)(i)), one count of

felony resisting or obstructing a peace officer causing injury (id. § 31-1(a-7)), two counts of

misdemeanor resisting or obstructing a peace officer (id. § 31-1(a)), and four counts of domestic

battery (id. § 12-3.2(a)(1), (a)(2)). (The State later nol-prossed the domestic battery charges.)

¶5 Count I, at issue here, charged aggravated battery to a peace officer and alleged that

defendant, “while committing a battery, *** knowingly caused great bodily harm *** to ***

Sergeant Nathan Herman, in that said defendant pushed his body into Sergeant Herman’s body,

knowing Sergeant Herman to be a peace officer performing his official duties.” 1

¶6 On February 20, 2024, the matter proceeded to a bench trial at which the following relevant

evidence was presented. Herman testified that, on February 3, 2022, he was a sergeant with the

1 The second and third counts of aggravated battery to a peace officer alleged that defendant

“knowingly made contact of an insulting and provoking nature with” or “knowingly caused bodily harm

to” Herman (counts II and III, respectively) in that defendant “pushed his body into *** Herman’s body,

knowing *** Herman to be a peace officer performing his official duties.” Count IV charged aggravated

battery (without regard to Herman’s status as a peace officer) in that defendant knowingly causing great

bodily harm to Herman. Count V charged aggravated assault in that defendant “knowingly engaged in

conduct which placed *** Herman in reasonable apprehension of receiving a battery, knowing *** Herman

to be a peace officer performing his official duties, in that *** defendant made statements that he had a

concealed weapon before quickly removing his hands from his clothing and swinging an unknown object

toward *** Herman.”

-2- 2025 IL App (2d) 240312-U

West Dundee Police Department. At about 9:40 p.m., he was dispatched to the Extended Stay

America hotel in West Dundee to investigate a disturbance. He arrived at the location along with

Officer Lauren Rickett, Officer Drew Morgan, and Officer Highland (first name not given). The

officers were wearing full police uniforms. They located the source of the disturbance: two

individuals arguing and yelling in Room 246. Morgan knocked on the door and announced the

police. Defendant opened the door and “appeared to be angry or upset.” A female, later identified

as Elizabeth Buhmann, was also present. Buhmann had “[s]cratch marks on her face.” Buhmann

exited the room, and Morgan and Highland walked down the hallway with her while Herman and

Rickett remained at the door with defendant.

¶7 Herman asked defendant “what’s going on” and requested his name. Defendant responded,

“T-Nasty.” Defendant, who was standing in the doorway, “focused” on Rickett and “started

making comments about her.” Herman saw defendant “manipulating something” in his “hoodie

pocket,” so he asked defendant to take his hands out of his pockets for “[s]afety reasons.”

Defendant responded, “I don’t know, it’s a concealed weapon.” Herman again asked defendant to

take his hands out of his pockets. Defendant was “moving something in his hoodie pocket and then

he just pull[ed] it out with his right hand and [swung] it towards [Herman’s] head.” Herman saw

a red object in defendant’s hand and thought it was a knife. Defendant was standing an “arm’s

length” away from Herman and came close to striking him. Herman grabbed defendant’s right

wrist as Rickett grabbed defendant’s right hand. Once Rickett had defendant’s right hand, Herman

switched and grabbed defendant’s left hand.

¶8 Herman and Rickett attempted to handcuff defendant, but defendant resisted. Counsel

inquired, “How was [defendant] resistant?” Herman responded:

-3- 2025 IL App (2d) 240312-U

“As we go out, this happened in the doorframe. We both have an arm and we move

him to the opposite wall *** of the hotel room in the hallway. And we’re kind of pushing

up against him and he’s continuously trying to reach into his hoodie pocket at that point.”

Eventually, they were able to pin defendant against the wall opposite the door. Herman was

standing “[o]ffset to [defendant’s] back-left side.” Herman “had [defendant’s] left arm with [his]

right arm.” Herman’s right arm was extended almost straight out from his shoulder, and he was

leaning to his left side. Defendant’s back left shoulder was “in the area between [Herman’s]

shoulder and [his] elbow on [his] right arm.” According to Herman, defendant kept “trying to reach

his hand in his hoodie and then he ke[pt] moving around. And as [he was] doing that, he bump[ed]

into [Herman].” Defendant’s “back-left shoulder area” made contact with the area between

Herman’s right shoulder and elbow.

¶9 Herman further testified:

“Q. *** And does he bump you softly or does by [sic] bump you with some force?

A. No. There’s force because he’s moving around.

Q. Okay. And was it a bump just like he was wiggling back and forth or was it more

of a direct action into your arm?

A. It was just he’s pulling away trying to get into his hoodie pocket as he’s flailing

around and hits me with his shoulder.”

Later, on redirect examination, Herman testified that defendant “pushed back off the wall ***

when [Herman’s] arm was up against him.”

¶ 10 Herman described what happened when defendant made contact with Herman’s arm:

“Q. Okay.

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Bluebook (online)
2025 IL App (2d) 240312-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-hyde-illappct-2025.