People v. Williams

2019 IL App (3d) 160132
CourtAppellate Court of Illinois
DecidedApril 11, 2019
Docket3-16-0132
StatusUnpublished
Cited by2 cases

This text of 2019 IL App (3d) 160132 (People v. Williams) 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. Williams, 2019 IL App (3d) 160132 (Ill. Ct. App. 2019).

Opinion

2019 IL App (3d) 160132

Opinion filed April 11, 2019 ____________________________________________________________________________

IN THE

APPELLATE COURT OF ILLINOIS

THIRD DISTRICT

THE PEOPLE OF THE STATE OF ) Appeal from the Circuit Court ILLINOIS, ) of the 14th Judicial Circuit, ) Henry County, Illinois Petitioner-Appellee, ) ) Appeal No. 3-16-0132 v. ) Circuit No. 14-DT-258 ) BOB WILLIAMS, ) Honorable ) Peter W. Church Defendant-Appellant. ) Judge, Presiding ______________________________________________________________________________

JUSTICE O’BRIEN delivered the judgment of the court, with opinion. Justices Carter and McDade concurred in the judgment and opinion. _____________________________________________________________________________

OPINION

¶1 Defendant Bob Williams was arrested by officers with the Kewanee Police Department

and charged with driving under the influence after he crashed his vehicle into a guardrail and left

the accident scene. Following his conviction, he appealed, alleging the Kewanee police were

without jurisdiction to arrest him. We affirm.

¶2 FACTS

¶3 On December 12, 2014, defendant Bob Williams was arrested by the Kewanee police

after he was found walking down the road one-half mile from where he had crashed his vehicle into the guardrail at Route 34 and Kentville Road. He was charged by complaint with driving

under the influence (DUI) (625 ILCS 5/11-501(a)(4) (West 2014)); failure to provide immediate

notice of an accident (625 ILCS 5/11-407 (West 2014)); leaving the scene of an accident with

vehicle damage (625 ILCS 5/11-402 (West 2014)); failure to reduce speed to avoid an accident

(625 ILCS 5/11-601(a) (West 2014)); and failure to wear a seat belt (625 ILCS 5/12-603 (West

2014)).

¶4 A jury trial took place. The parties stipulated that Williams was under the influence of

alcohol when he was found walking down the shoulder of the road by the Kewanee police

officers. Rebecca Barnett testified that she lived on Route 34 outside the Kewanee city limits. On

December 12, 2014, she was in the driveway when she heard a loud banging noise and assumed

there had been an accident. She investigated and discovered a vehicle had hit the guardrail on

Route 34 and was sideways in the road. There was no one in the vehicle. She called 911 and

talked to some passersby who had also stopped. She was unsure whether the accident site was

within the Kewanee city limits but she did not believe it was.

¶5 Ronika Long testified that she was on Route 34 on December 12, 2014, and saw a vehicle

sideways in the westbound lane crashed into the guardrail. She saw a person standing outside the

vehicle next to the driver’s door who looked like he was trying to get into the vehicle. The man

then fled. She described him as a white male with a mustache, wearing a white T-shirt and jeans,

and without a coat.

¶6 William Rivord testified. He was a lieutenant with the Kewanee Police Department who

responded to the 911 call. He observed the vehicle’s airbags were not deployed and the seat belts

were in the upright retracted position, meaning they had not been worn. He spoke to witness

Long and put out a dispatch with the driver’s description. Andrew Kingdon, a Kewanee Police

2 Department patrol officer, testified. He responded to the dispatch regarding the accident,

participated in the search of Williams’s person and found a set of car keys on Williams. He later

successfully used the keys on the crashed vehicle.

¶7 Nicholas Welgat, a sergeant with the Kewanee Police Department, testified. He was

dispatched to respond to the accident and found Williams walking on the shoulder of the road

one-half mile east of the crash site. Welgat noticed Williams smelled strongly of alcoholic

beverage, and had glassy eyes, slurred speech, and trouble talking, standing and walking. Welgat

searched Williams, discovering a pipe and pill key fob with burnt residue in them. Both items

field-tested positive for the presumptive presence of cannabis. Welgat arrested Williams for DUI.

On cross-examination, Welgat stated the accident scene was outside the city limits of Kewanee

in unincorporated Henry County.

¶8 At the close of evidence, the defense orally moved to dismiss the charges on the basis

that the Kewanee police lacked jurisdiction to arrest Williams outside of the Kewanee city limits.

The trial court granted the motion on the charge of failure to report an accident, finding the

accident occurred outside the city limits and notification was required to state or county law

enforcement but not to Kewanee. The trial court denied the motion to dismiss regarding the other

charges. The jury found Williams guilty of DUI, failure to wear a seatbelt and failure to reduce

speed to avoid an accident. Although the parties indicate the jury also found Williams guilty of

possession of cannabis and paraphernalia, the citations and jury verdicts for those charges are not

in the record.

¶9 Williams filed posttrial motions to dismiss and for a new trial. In arguing his motion to

dismiss, Williams submitted that the Kewanee police officers lacked the authority to make an

extraterritorial arrest. The State argued that the police were not outside their jurisdiction and

3 presented an annexation agreement indicating the accident site was within Kewanee’s city limits

and a letter explaining that Rivord and Welgat were deputized as Henry County Sheriff’s

Department members and had countywide jurisdiction.

¶ 10 The trial court denied Williams’s posttrial motions to dismiss and for a new trial. The

court found the Kewanee officers had jurisdiction as they were “personally aware” an offense

had been committed. The court further considered that Williams was required to remain at the

scene and the officers became immediately aware on arriving that the driver did not remain, thus

giving them authority to question and arrest Williams. The court did not reach either the

annexation or deputization issues. The court sentenced Williams to a 12-month term of

conditional discharge, 5 days in the county jail and fines. Williams appealed.

¶ 11 ANALYSIS

¶ 12 The issue on appeal is whether the trial court erred when it denied Williams’s motion to

dismiss because the Kewanee police lacked jurisdiction. He argues that the arresting Kewanee

officer lacked jurisdiction to stop and arrest him because the accident and arrest occurred outside

the city limits of Kewanee and the circumstances did not establish authority for an extraterritorial

arrest.

¶ 13 An officer may arrest a person without a warrant when he has “reasonable grounds to

believe that the person is committing or has committed an offense.” 725 ILCS 5/107-2(1)(c)

(West 2014); People v. Jackson, 2014 IL App (3d) 120239, ¶ 85. A police officer may make a

stop and arrest outside his primary jurisdiction if (1) the initial offense occurred within the

officer’s proper jurisdiction and pursuit or investigation led outside the jurisdiction or (2) the

officer becomes “personally aware” a person has immediately committed an offense.

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Related

People v. Arnold
2026 IL App (1st) 232350 (Appellate Court of Illinois, 2026)
People v. Sanchez
2021 IL App (3d) 170410 (Appellate Court of Illinois, 2021)
People v. Williams
2019 IL App (3d) 160132 (Appellate Court of Illinois, 2019)

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Bluebook (online)
2019 IL App (3d) 160132, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-williams-illappct-2019.