People v. Okapal

2020 IL App (2d) 180034-U
CourtAppellate Court of Illinois
DecidedMarch 20, 2020
Docket2-18-0034
StatusUnpublished

This text of 2020 IL App (2d) 180034-U (People v. Okapal) 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. Okapal, 2020 IL App (2d) 180034-U (Ill. Ct. App. 2020).

Opinion

2020 IL App (2d) 180034-U No. 2-18-0034 Order filed March 20, 2020

NOTICE: This order was filed under Supreme Court Rule 23 and may not be cited as precedent by any party 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. 16-CM-3309 ) SAMANTHA OKAPAL, ) Honorable ) Linda S. Abrahamson Defendant-Appellant. ) Judge, Presiding. ______________________________________________________________________________

JUSTICE ZENOFF delivered the judgment of the court. Justices Jorgensen and Schostok concurred in the judgment.

ORDER

¶1 Held: The trial court did not abuse its discretion in admitting video evidence taken at the time of the arrest: coupled with other evidence, the police car’s dashcam video was not unduly prejudicial and provided a continuing narrative of the events giving rise to the offense of resisting a peace officer.

¶2 Following a bench trial, defendant, Samantha Okapal, was convicted of resisting a peace

officer (720 ILCS 5/31-1(a) (West 2016)). She appeals, contending that she was unreasonably

prejudiced by the trial court’s consideration of a dashcam video on which she can be heard cursing

at and threatening the arresting officers. We affirm.

¶3 I. BACKGROUND 2020 IL App (2d) 180034-U

¶4 Defendant moved in limine to exclude from evidence portions of a police dashcam video.

She contended that the video of events after she was handcuffed was irrelevant or more prejudicial

than probative. The trial court denied the motion, finding that the video was probative of “motive,

absence of mistake,” and “her mental state.”

¶5 At trial, Aurora police officer Dominic Tamberelli testified that he and officer Bradley

Vonhoff were dispatched to a reported domestic disturbance. They arrived separately and

encountered defendant, her mother, Leann Okapal, and her sister, Andrea Okapal. Defendant was

arguing with her mother and using profanity. The officers learned that the argument began when

Leann took defendant’s video-game remote controller and defendant responded by taking Leann’s

cigarettes. Tamberelli decided that the parties were resolving the situation on their own, so the

officers left the house.

¶6 As the officers walked back to their respective squad cars, defendant threw something out

the front door and ran onto the porch screaming profanities at Andrea. While defendant and

Andrea argued on the porch, Leann locked the front door. Defendant ran to the front door and,

finding it locked, responded with a string of profanity. She ran to the rear door and found that it,

too, was locked. She returned to the front porch and banged on and kicked the front door,

“swearing throughout the process.” She said that if Leann did not open the door, she would break

it down and “[b]ust her teeth out.”

¶7 Defendant started to walk down the porch steps. Tamberelli, who was standing at the

bottom of the steps, said, “ ‘You’re coming with us now.’ ” Defendant swore and walked past

Tamberelli toward Vonhoff. Tamberelli told defendant that she was under arrest for disorderly

conduct. Vonhoff reached for her left arm, but she spun away from him. Tamberelli then grabbed

her left arm as Vonhoff grabbed her right. Defendant pulled her arms in and dropped her body

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weight. The officers pushed her to the ground and told her to put her hands behind her back.

Defendant refused, keeping her arms curled under her chest until the officers forced them into

position to handcuff her. Defendant was uttering profanities the entire time.

¶8 Vonhoff testified similarly. He added that the officers attempted to let her up, but she tried

to kick Vonhoff, so they pushed her down on her stomach while Vonhoff held her legs. He held

her wrist so she would stop rolling around and trying to squirm out of the handcuffs. As he did

so, she pinched his arms 50 to 60 times.

¶9 Eventually a police transport van arrived. As defendant was already “agitated” with

Tamberelli and Vonhoff, they allowed the transport officers to take control of her.

¶ 10 The State then played the dashcam video. Defendant was visible on the video for only a

short time while being escorted to the van. However, she could be heard complaining about pain

in her wrists from the handcuffs, yelling obscenities at the officers, and spitting or clearing her

throat. She also threatened to kill the officers, to spit on one of them, to sue them, and to set fire

to the house.

¶ 11 Leann and Andrea testified for the defense that they did not hear the officers tell defendant

that she was under arrest. They did not see defendant try to kick the officers. The court found

defendant guilty, finding the officers credible. Conversely, the court found the defense witnesses,

defendant’s relatives, biased in defendant’s favor. The court denied defendant’s posttrial motion

and sentenced her to 6 days in jail and 14 months of conditional discharge. Defendant timely

appeals.

¶ 12 I. ANALYSIS

¶ 13 Defendant contends that she is entitled to a new trial because the trial court erred by

considering the video. On appeal, she concedes that the video was relevant, but contends that its

-3- 2020 IL App (2d) 180034-U

probative value was minimal and outweighed by the prejudice it caused defendant. She reasons

that the officers’ testimony was sufficient to prove that she resisted and, therefore, the video was

cumulative evidence that should have been excluded. Moreover, nothing of substance can be seen

on the video, but she can be heard cursing, spitting, and threatening the officers. She contends that

this was not part of the charged conduct and served only to place her in a bad light.

¶ 14 The admission of evidence is within the trial court’s discretion and, thus, we review such

rulings only for an abuse of discretion. People v. Williams, 181 Ill. 2d 297, 313 (1998). The

admissibility of evidence may depend upon whether its probative value outweighs its prejudicial

effect on the defense. Id. at 314. However, otherwise relevant evidence will not be excluded

merely because it may prejudice the accused. Id. Further, evidence may be admitted even if it is

cumulative to oral testimony covering the same issue. Id. at 315.

¶ 15 We conclude that the trial court did not abuse its discretion in determining that the video

was not unduly prejudicial. Defendant cites no case in which a video of a defendant’s arrest or its

immediate aftermath was deemed unduly prejudicial.

¶ 16 Defendant contends that she was prejudiced by evidence of her profanity, spitting, and

threats directed toward the officers. Generally, the presence of irrelevant, incompetent,

immaterial, or obscene matter in a recording will not bar it from evidence so long as the

objectionable portions are not prejudicial. People v. Nahas, 9 Ill. App. 3d 570, 578 (1973).

¶ 17 In People v. Brown, 83 Ill. App. 3d 741, 745 (1980), the court held that the defendant was

not prejudiced by testimony about his belligerent behavior and abusive language at the police

station. In People v. Wright, 20 Ill. App.

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Cite This Page — Counsel Stack

Bluebook (online)
2020 IL App (2d) 180034-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-okapal-illappct-2020.