People v. Williams

2019 IL App (3d) 160132
Appellate Court of Illinois·Decided October 16, 2019·No. 3-16-0132·Unpublished·Cited by 1 cases

Opinion

2019 IL App (3d) 160132

Opinion filed October 16, 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 various offenses including 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 (626 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 enter 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 spoke to witness Long and put out a dispatch with the driver’s

description. Andrew Kingdon, a Kewanee Police Department patrol officer, testified. He

responded to the dispatch regarding the accident, participated in the search of Williams’s person,

2 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 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 an 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

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

3 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. We affirmed his

conviction, finding the annexation agreement established the arrest was not extraterritorial.

People v. Williams, 2019 IL App (3d) 160132, ¶ 16. Williams petitioned for rehearing, which

motion this court granted.

¶ 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. Williams further argues the annexation agreement did not establish the arrest was within

the Kewanee city limits. He maintains that the charges against him should have been dismissed

based on lack of jurisdiction to arrest.

¶ 13 In granting the motion for rehearing, we asked the parties to discuss whether the State

needed a valid arrest in order to prosecute Williams. Both the State and Williams agree that the

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People v. Williams
2019 IL App (3d) 160132 (Appellate Court of Illinois, 2019)