People v. Mussario

2025 IL App (3d) 240611-U
CourtAppellate Court of Illinois
DecidedSeptember 2, 2025
Docket3-24-0611
StatusUnpublished

This text of 2025 IL App (3d) 240611-U (People v. Mussario) 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. Mussario, 2025 IL App (3d) 240611-U (Ill. Ct. App. 2025).

Opinion

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

2025 IL App (3d) 240611-U

Order filed September 2, 2025 ____________________________________________________________________________

IN THE

APPELLATE COURT OF ILLINOIS

THIRD DISTRICT

THE PEOPLE OF THE STATE OF ) Appeal from the Circuit Court ILLINOIS, ) of the 13th Judicial Circuit, ) La Salle County, Illinois, Plaintiff-Appellee, ) ) Appeal No. 3-24-0611 v. ) Circuit No. 22-MT-1434 ) MICHAEL A. MUSSARIO, ) Honorable ) Michael C. Jansz, Defendant-Appellant. ) Judge, Presiding. ____________________________________________________________________________

PRESIDING JUSTICE BRENNAN delivered the judgment of the court. Justices Peterson and Anderson concurred in the judgment. ____________________________________________________________________________

ORDER

¶1 Held: The evidence presented at trial was sufficient to establish defendant drove or operated a motor vehicle to sustain his convictions.

¶2 Following a bench trial, defendant, Michael A. Mussario, was found guilty of various

offenses under the Illinois Vehicle Code (Code) (625 ILCS 5/1-100 et seq. (West 2022)).

Defendant appeals, arguing the evidence was insufficient to sustain his convictions as the State

failed to prove he was driving or in actual physical control of a motor vehicle. We affirm. ¶3 I. BACKGROUND

¶4 On December 26, 2022, the Illinois State Police issued defendant citations for driving while

his license was suspended (id. § 6-303(a)), operating a motor vehicle without an ignition interlock

device as required by restriction (id. § 6-206.2(a)), operating an uninsured motor vehicle (id. § 3-

707(a)), and improper lane usage by crossing a lane boundary unsafely (id. § 11-709(a)).

¶5 On April 26, 2024, the matter proceeded to a bench trial. Officer Tavis Fivek testified he

was on patrol the evening of December 26, 2022. At approximately 2 a.m., he was dispatched to a

report of a vehicle in the trees off Interstate 80. When Fivek arrived at the scene, he observed a

vehicle in the trees and tire tracks leading from the roadway to the grass where the vehicle was

located. The road was wet. Fivek approached the vehicle and observed defendant sitting behind

the steering wheel in the driver’s seat. Defendant produced his driver’s license but was unable to

provide any proof of insurance. Fivek believed he asked defendant how the vehicle ended up in

the trees, but he could not recall what explanation defendant provided. Fivek learned from dispatch

that defendant had a suspended license and a breath alcohol ignition interlock device (BAIID)

restriction. Fivek did not observe a BAIID in the vehicle. The State admitted into evidence a

certified copy of defendant’s driving abstract from the Illinois Secretary of State. The abstract

provided, on December 26, 2022, defendant had a suspended driver’s license and a valid

monitoring device driving permit. The court found defendant guilty of all counts.

¶6 On May 31, 2024, defendant filed a motion for judgment notwithstanding the verdict or a

new trial. Among other things, defendant argued the State failed to establish that he was in actual

physical control of a motor vehicle. The court held a hearing on the motion, which it denied. The

court explained the circumstantial evidence gave rise to the reasonable inference that defendant

was driving the vehicle when he veered off the road into the ditch by the trees.

2 ¶7 On October 18, 2024, the court held a sentencing hearing. In mitigation, defense counsel

stated that, while not excusing defendant’s operation of a motor vehicle or the removal of the

BAIID on the night in question, defendant was driving to leave Illinois and receive medical

treatment. Defendant’s conviction for operating a motor vehicle without an ignition interlock

device merged, and the court imposed a sentence of one year of conditional discharge for driving

on a suspended license and one year of court supervision for operating an uninsured motor vehicle

and improper lane usage. Defendant appeals.

¶8 II. ANALYSIS

¶9 On appeal, defendant argues the evidence was insufficient to sustain his convictions

because it did not establish beyond a reasonable doubt that he was driving or in actual physical

control of a motor vehicle. When reviewing a challenge to the sufficiency of the evidence, we must

view the evidence in the light most favorable to the prosecution and determine whether any rational

trier of fact could have found the essential elements of the offense beyond a reasonable doubt.

People v. Gray, 2017 IL 120958, ¶ 35. The trier of fact determines the credibility of the witnesses,

assigns weight to the testimony, resolves conflicts in the evidence, and draws reasonable inferences

from basic facts to ultimate facts. People v. Brown, 2013 IL 114196, ¶ 48. A conviction will not

be reversed unless the evidence is so unreasonable, improbable, or unsatisfactory that it creates a

reasonable doubt of the defendant’s guilt. People v. Siguenza-Brito, 235 Ill. 2d 213, 225 (2009).

The same standard applies whether the evidence is direct or circumstantial. Brown, 2013 IL

114196, ¶ 49.

¶ 10 To prove defendant guilty of driving while his license was suspended, the State was

required to establish that defendant drove or was in actual physical control of a motor vehicle upon

any highway in Illinois when defendant’s driver’s license was suspended. 625 ILCS 5/6-303(a)

3 (West 2022). While this offense allows the State to demonstrate either defendant drove or was in

actual physical control of a motor vehicle, the other three offenses for which defendant was

convicted required the State to prove defendant operated (id. §§ 6-206.2(a), 3-707(a)) or drove a

motor vehicle (id. § 11-709(a)). 1 Defendant contends the State failed to prove either proposition—

that he drove or operated a vehicle or was in actual physical control of a motor vehicle. Defendant

does not challenge any other element with respect to these convictions, and therefore, we forego

any discussion of the other requisite elements in our analysis.

¶ 11 The element of driving or operating a motor vehicle may be proven by circumstantial

evidence alone. People v. Call, 176 Ill. App. 3d 571, 576 (1988). “Circumstantial evidence is proof

of facts and circumstances from which the trier of fact may infer other connected facts that

reasonably and usually follow according to common experience.” People v. McAndrew, 2024 IL

App (1st) 230881, ¶ 45. Thus, “observation of a defendant in the act of driving is not an

indispensable prerequisite for a conviction.” People v. Lurz, 379 Ill. App. 3d 958, 969 (2008).

¶ 12 Here, the evidence clearly established defendant drove or operated a motor vehicle, which

is sufficient to sustain each conviction. Fivek testified he was dispatched at approximately 2 a.m.

to a report of a vehicle that was in the trees off the interstate. When he arrived at the scene, he

observed tire tracks leading off the interstate to where the vehicle was located among the trees,

and the road was wet. Fivek located defendant in the vehicle alone and in the driver’s seat. When

considering the time, the road condition, the vehicle’s location off an interstate, tire tracks from

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Related

People v. Lurz
885 N.E.2d 433 (Appellate Court of Illinois, 2008)
People v. Call
531 N.E.2d 451 (Appellate Court of Illinois, 1988)
People v. Siguenza-Brito
920 N.E.2d 233 (Illinois Supreme Court, 2009)
People v. Wheeler
871 N.E.2d 728 (Illinois Supreme Court, 2007)
People v. Brown
2013 IL 114196 (Illinois Supreme Court, 2013)
People v. Gray
2017 IL 120958 (Illinois Supreme Court, 2017)
People v. McAndrew
2024 IL App (1st) 230881 (Appellate Court of Illinois, 2024)

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Bluebook (online)
2025 IL App (3d) 240611-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-mussario-illappct-2025.