Case Law People v. Casler

People v. Casler

Document Cited Authorities (39) Cited in (46) Related

James E. Chadd, State Appellate Defender, Ellen J. Curry, Deputy Defender, and Daniel R. Janowski, Assistant Appellate Defender, of the Office of the State Appellate Defender, of Mt. Vernon, for appellant.

Kwame Raoul, Attorney General, of Springfield (Jane Elinor Notz, Solicitor General, and Michael M. Glick and Mitchell J. Ness, Assistant Attorneys General, of Chicago, of counsel), for the People.

OPINION

JUSTICE NEVILLE delivered the judgment of the court, with opinion.

¶ 1 Following a jury trial in the circuit court of Jackson County, defendant, Rasheed Casler, was convicted of obstructing justice by furnishing false information ( 720 ILCS 5/31-4(a)(1) (West 2014)). The appellate court affirmed. 2019 IL App (5th) 160035, 433 Ill.Dec. 1, 130 N.E.3d 566. This court allowed defendant's petition for leave to appeal ( Ill. S. Ct. R. 315(a) (eff. July 1, 2018)). We now reverse the judgments of the appellate and circuit courts and remand the cause to the circuit court for further proceedings.

¶ 2 I. BACKGROUND

¶ 3 Defendant was charged in a three-count information with possessing less than 15 grams of cocaine (count I) and less than 5 grams of methamphetamine (count II). Count III charged defendant with obstructing justice "in that the defendant (Rasheed Casler) knowingly, with the intent to prevent his arrest on warrants, provided false information to Sgt. Guy Draper in that he said his name was Jakuta King Williams." Only count III is at issue in this appeal.

¶ 4 Defendant was tried before a jury. The State's case, as it pertained to the obstructing justice charge, was essentially as follows. Carbondale police sergeant Guy Draper testified that on March 6, 2015, he and Patrolman Blake Harsy were both in uniform and on foot patrol at various hotels throughout Carbondale. At 12:45 a.m., they were on the second floor of the Quality Inn. As they approached room 210, the door quickly opened, and defendant emerged, looked at Sergeant Draper, and then went back into the room and slammed the door. Draper was not sure who defendant was but remembered him as being someone with whom he had dealings.

¶ 5 Sergeant Draper testified that when defendant slammed the door, Patrolman Harsy smelled the odor of burnt cannabis emanating from the room. Sergeant Draper approached the door and smelled it also. Draper knocked on the door, and Brianna Wyatt opened it. Standing in the doorway, Draper smelled a stronger cannabis odor. Draper saw two men whom he recognized and two women whom he did not recognize. He called for backup. The four individuals wanted to leave the room, but Draper did not allow them to do so.

¶ 6 Sergeant Draper testified that he did not see defendant in the room, and the bathroom door was closed. Draper explained that he had experienced people in hotel rooms hiding in bathrooms to evade apprehension and hide or destroy evidence. Still standing in the doorway, Draper knocked on the hotel room door, announced his office, and said, "Anybody in the bathroom, identify yourself."

¶ 7 Sergeant Draper testified that defendant responded essentially that he was defecating. Sergeant Draper again commanded defendant to identify himself, and defendant responded that his name was Jakuta King Williams. Draper asked defendant for identification. Defendant responded that he had no identification and said that he was from Virginia. Patrolman Harsy relayed the name to the dispatch center, but no record of a person with that name was found. Draper testified that he was initially fooled by the false name.

¶ 8 Sergeant Draper testified that he ordered defendant to open the door and said, if defendant flushed the toilet, Draper would enter the bathroom and seize him. Draper did not hear the toilet flush, and as far as he knew, defendant did not try to destroy evidence in the bathroom.

¶ 9 Sergeant Draper testified that defendant eventually emerged from the bathroom. Draper recognized defendant and remembered his name because he had previously arrested him. Draper asked defendant whether he was Rasheed Casler, and defendant did not respond. One of the officers relayed defendant's name to the dispatch center, which responded that defendant had an outstanding warrant. Sergeant Draper arrested defendant. Nothing interfered with Draper's ability to arrest defendant. Defendant did not attempt to resist or flee from Draper.

¶ 10 Sergeant Draper testified that he observed toilet paper in the toilet but did not see any human waste or contraband. During a postarrest search of the room, he and other police officers discovered defendant's green hoodie lying on a bed. They found in the hoodie a wallet with an Illinois identification card bearing the name of Rasheed Casler.

¶ 11 Patrolman Harsy testified. Both he and Sergeant Draper saw the hotel room door open and saw defendant emerge from the room, look at Sergeant Draper, and then reenter the room and shut the door. Harsy smelled the odor of burnt cannabis. Sergeant Draper knocked on the door, and one of the occupants, Brianna Wyatt, opened the door. Patrolman Harsy learned from Wyatt that the actual registered guest to that room had left. Harsy went downstairs to the manager's desk and spoke with the manager on duty. Harsy learned the name of the room's registered guest. Harsy returned to the room less than 10 minutes later. Harsy saw several officers standing in front of the door and heard a certain tone on the police radio, which indicated that a name submitted to a police database search has an outstanding warrant. The officers then entered the room and took defendant into custody.

¶ 12 Shanique Lincoln testified as follows. She was one of the individuals with defendant in the hotel room. She could not remember many details from the investigation because she had been drinking tequila and smoking marijuana. Lincoln testified that she signed a written statement that night. However, she further testified that she "felt forced, pushed into it" because she was arrested that night for possession of cannabis and she felt threatened and frightened. Over objection, her statement was published to the jury. In the statement, Lincoln averred that defendant "looked out the door and said wo [sic ] and closed the door."

¶ 13 The defense case consisted of defendant's testimony. Defendant arrived at the Quality Inn on that date shortly after midnight. He was drunk from tequila. He went to room 210 because his friends were there. He continued drinking tequila in the hotel room. He became nauseated and tried to find the bathroom. However, he opened the wrong door into the hallway. He opened the door and shut it. He did not step into the hallway and did not see any law enforcement in the hallway.

¶ 14 Defendant found the bathroom and began having diarrhea. Defendant heard someone ask who was in there. Defendant thought it was one of his friends joking with him, so he answered Jakuta King Williams. Defendant did not know there were police officers outside the bathroom door when he shouted that he was Jakuta King Williams. Defendant was not attempting to avoid being arrested by giving the false name. Defendant did not enter the bathroom to avoid arrest and did not intend to flush any contraband while in the bathroom. When defendant was told to open the door, he realized that it was the police. Defendant opened the door while still seated on the toilet. Defendant then recognized Sergeant Draper, who had arrested him in 2013. Defendant finished using the bathroom and exited without flushing the toilet.

¶ 15 At the close of trial, the jury acquitted defendant of the drug possession charges and found him guilty of the obstructing justice charge. On January 20, 2016, defendant was sentenced to 90 days in the Jackson County Jail, beginning that day, and two years of probation.

¶ 16 On July 1, 2019, the appellate court affirmed the judgment of conviction. The sole issue on appeal was whether the State proved defendant guilty of the offense of obstructing justice in that defendant, knowingly and with the intent to prevent his arrest on warrants, provided false information to Draper by identifying himself as Jakuta King Williams. 2019 IL App (5th) 160035, ¶¶ 23-25, 433 Ill.Dec. 1, 130 N.E.3d 566. Defendant maintained that the evidence was insufficient to prove that he had the requisite intent to prevent his apprehension. Id. ¶¶ 26-27. Rejecting this contention, the appellate court held that circumstantial evidence was sufficient to prove that defendant intended to avoid apprehension and gave Draper the false name in an effort to do so. Id. ¶¶ 28-33.

¶ 17 Defendant alternatively argued that the evidence was insufficient to support his conviction of obstructing justice because his giving of the false name did not materially impede the administration of justice. In support of his argument, defendant cited People v. Taylor , 2012 IL App (2d) 110222, 362 Ill.Dec. 38, 972 N.E.2d 753, which in turn relied on this court's decision in People v. Comage , 241 Ill. 2d 139, 349 Ill.Dec. 119, 946 N.E.2d 313 (2011). 2019 IL App (5th) 160035, ¶¶ 37-40, 433 Ill.Dec. 1, 130 N.E.3d 566. Rejecting this argument, the appellate court distinguished this court's decision in Comage and refused to follow Taylor . Id. ¶¶ 41-49. The appellate court held that the State was not required to prove that the false name furnished by defendant materially impeded his arrest. Id. ¶ 49.

¶ 18 Defendant appeals to this court. We note that defendant was sentenced in January 2016. Therefore, he could already have served his sentence. "However, the nullification of a conviction unquestionably may have important consequences to a defendant, whether or not the attendant sentence has been served. In such circumstances, the probability that a criminal defendant may suffer collateral legal...

5 cases
Document | Illinois Supreme Court – 2021
Evans v. Cook Cnty. State's Attorney
"...intent. All other canons and rules of statutory construction are subordinate to this principle. People v. Casler , 2020 IL 125117, ¶ 24, 450 Ill.Dec. 415, 181 N.E.3d 767. The most reliable indicator of legislative intent is the language of the statute, given its plain and ordinary meaning. ..."
Document | Appellate Court of Illinois – 2022
People v. Fields
"...whole, construing words and phrases in light of other relevant statutory provisions and not in isolation." People v. Casler , 2020 IL 125117, ¶ 24, 450 Ill.Dec. 415, 181 N.E.3d 767. Moreover, courts " ‘will not hesitate to read into the sense of some section or provision a qualifying or exp..."
Document | Illinois Supreme Court – 2024
People v. Fair
"...asserts that the standard of review should be de novo when reviewing the interpretation of a statute (see People v. Caslor, 2020 IL 125117, ¶ 22, 450 Ill.Dec. 415, 181 N.E.3d 767) and otherwise believes the manifest error standard applies as the "typical appellate standard of review for fin..."
Document | Appellate Court of Illinois – 2022
People v. Taylor
"...primary objective of statutory construction is to ascertain and give effect to the legislature's intent. People v. Casler , 2020 IL 125117, ¶ 24, 450 Ill.Dec. 415, 181 N.E.3d 767. All other rules of statutory construction are subordinate to this principle. Id. "In determining the intent of ..."
Document | Illinois Supreme Court – 2024
People v. Wells
"...719. In doing so, we presume that the legislature did not intend absurdity, inconvenience, or injustice. People v. Casler, 2020 IL 125117, ¶ 24, 450 Ill.Dec. 415, 181 N.E.3d 767. The construction of a statute is an issue of law, which is subject to de novo review. Manago, 2017 IL 121078, ¶ ..."

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5 cases
Document | Illinois Supreme Court – 2021
Evans v. Cook Cnty. State's Attorney
"...intent. All other canons and rules of statutory construction are subordinate to this principle. People v. Casler , 2020 IL 125117, ¶ 24, 450 Ill.Dec. 415, 181 N.E.3d 767. The most reliable indicator of legislative intent is the language of the statute, given its plain and ordinary meaning. ..."
Document | Appellate Court of Illinois – 2022
People v. Fields
"...whole, construing words and phrases in light of other relevant statutory provisions and not in isolation." People v. Casler , 2020 IL 125117, ¶ 24, 450 Ill.Dec. 415, 181 N.E.3d 767. Moreover, courts " ‘will not hesitate to read into the sense of some section or provision a qualifying or exp..."
Document | Illinois Supreme Court – 2024
People v. Fair
"...asserts that the standard of review should be de novo when reviewing the interpretation of a statute (see People v. Caslor, 2020 IL 125117, ¶ 22, 450 Ill.Dec. 415, 181 N.E.3d 767) and otherwise believes the manifest error standard applies as the "typical appellate standard of review for fin..."
Document | Appellate Court of Illinois – 2022
People v. Taylor
"...primary objective of statutory construction is to ascertain and give effect to the legislature's intent. People v. Casler , 2020 IL 125117, ¶ 24, 450 Ill.Dec. 415, 181 N.E.3d 767. All other rules of statutory construction are subordinate to this principle. Id. "In determining the intent of ..."
Document | Illinois Supreme Court – 2024
People v. Wells
"...719. In doing so, we presume that the legislature did not intend absurdity, inconvenience, or injustice. People v. Casler, 2020 IL 125117, ¶ 24, 450 Ill.Dec. 415, 181 N.E.3d 767. The construction of a statute is an issue of law, which is subject to de novo review. Manago, 2017 IL 121078, ¶ ..."

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  • Build stronger arguments with verified citations and CERT citator that tracks case history and precedential strength

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