People v. Mehta
| Decision Date | 10 July 2020 |
| Docket Number | Appeal No. 3-18-0020 |
| Citation | 156 N.E.3d 608,441 Ill.Dec. 273,2020 IL App (3d) 180020 |
| Parties | The PEOPLE of the State of Illinois, Plaintiff-Appellee, v. Keval K. MEHTA, Defendant-Appellant. |
| Court | United States Appellate Court of Illinois |
James E. Chadd, Peter A. Carusona, and James Wozniak, of State Appellate Defender's Office, of Ottawa, for appellant.
James W. Glasgow, State's Attorney, of Joliet (Patrick Delfino and Thomas D. Arado, of State's Attorneys Appellate Prosecutor's Office, of counsel), for the People.
¶ 1 Defendant, Keval K. Mehta, appeals following his conviction for obstruction of a peace officer. He argues that the evidence presented by the State at his trial was insufficient to prove him guilty beyond a reasonable doubt of the charged offense. We affirm.
Defendant elected to proceed with a bench trial.
¶ 4 At trial, Stepien testified that on August 2, 2016, at approximately 12:05 a.m., he and his sergeant were dispatched to a parking lot in the area of Beaconridge Drive in Bolingbrook on reports that a man with a handgun was threatening another person. Officer Jason Mitchem and other officers were already on the scene when Stepien arrived. As Stepien pulled into the parking lot, his car was passed by a black SUV. Mitchem pointed at the SUV and instructed Stepien to stop it. Stepien pulled his squad car behind the SUV, effecting what he described as a "felony traffic stop" because a firearm was reportedly involved.
¶ 5 Per Stepien's instructions, the driver of the SUV rolled down his window, threw out the keys to the car, exited the vehicle, raised his hands, turned his back to Stepien, and walked backwards toward the officer. The driver was placed in handcuffs.
¶ 6 Defendant was a passenger in the SUV. After the driver of the SUV had been secured, Stepien instructed defendant to exit the vehicle with his hands raised. He also instructed defendant to turn around once he was out of the car. Stepien testified that defendant "flung the door open very aggressively." Defendant did not put his hands in the air and did not turn around. Stepien testified that he commanded defendant "[m]ultiple times" to turn around. Defendant responded by telling the officers "I don't have to do s* * *." Stepien testified that defendant did eventually walk forward to the officers, though he never turned around. He was placed into custody without further incident. Stepien noted that he did not personally observe defendant being placed in handcuffs because he was keeping his attention on the vehicle.
¶ 7 Stepien testified that he was wearing a vest carrier, which looks like a police uniform shirt but carries a bulletproof vest. He was driving an unmarked squad car but activated its flashing lights to effectuate the stop. He identified himself to defendant as a police officer. Stepien also testified that the area of Beaconridge Drive to which he responded was known for high gang activity. Because of this fact and the report of a gun, Stepien took all standard precautions when executing the traffic stop.
¶ 8 On cross-examination, Stepien estimated that his entire interaction with defendant likely lasted less than five minutes. On redirect, Stepien testified that it did not last longer than three minutes.
¶ 9 Mitchem testified that he responded to the vicinity of Beaconridge Drive on the night in question. Upon arrival, Mitchem met with the complainant, who told him that two men had been chasing him with a gun. As Mitchem was speaking with the complainant, a black SUV accelerated through the parking lot. The complainant indicated that the men with the gun were driving an SUV. Mitchem briefly gave chase on foot and then indicated to Stepien to stop the SUV. After Stepien had effectuated the stop, Mitchem ran to that area to assist.
¶ 10 Mitchem testified that the driver of the SUV was compliant with all of the officers' commands. He testified that defendant, however, was "[v]ery belligerent [and] would not follow directions." Specifically, he refused to turn away from the officers despite being commanded to do so. Defendant repeatedly stated that he was going to sue the police. Mitchem testified that he was eventually able to get close enough to defendant "to handcuff him without a struggle." He then turned defendant over to another officer "in order to finish clearing the car."
¶ 11 On cross-examination, Mitchem estimated that the interaction between Stepien and defendant did not last longer than three minutes. He could not say whether it was one minute or two minutes. He testified that it was not "the twenty seconds that we wanted it to take." On redirect, Mitchem described the stop as a "very high stress situation." He explained that defendant not turning away put himself (Mitchem) at risk. Mitchem noted that defendant's conduct "took away from our ability to investigate if there was anyone else in the car, if there was a gun in the area."
¶ 12 The court found defendant guilty and sentenced him to a term of 12 months' conditional discharge.
¶ 14 When a challenge is made to the sufficiency of the evidence at trial, we review to determine whether any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt. People v. Baskerville , 2012 IL 111056, ¶ 31, 357 Ill.Dec. 500, 963 N.E.2d 898 ; People v. Collins , 106 Ill. 2d 237, 261, 87 Ill.Dec. 910, 478 N.E.2d 267 (1985). In making this determination, we review the evidence in the light most favorable to the prosecution. Baskerville , 2012 IL 111056, ¶ 31, 357 Ill.Dec. 500, 963 N.E.2d 898. All reasonable inferences from the record in favor of the prosecution will be allowed. People v. Bush , 214 Ill. 2d 318, 327, 292 Ill.Dec. 926, 827 N.E.2d 455 (2005). The trier of fact is not required to seek out or accept any "possible explanations consistent with innocence and raise them to a level of reasonable doubt." People v. Campbell , 146 Ill. 2d 363, 380, 166 Ill.Dec. 932, 586 N.E.2d 1261 (1992).
¶ 15 Section 31-1(a) of the Criminal Code of 2012 (Code) holds that obstruction of a peace officer is committed where "[a] person who * * * resists or obstructs the performance by one known to the person to be a peace officer * * * of any authorized act within his or her official capacity." 720 ILCS 5/31-1(a) (West 2016). On appeal, defendant concedes that the State sufficiently proved that Stepien was a peace officer performing an authorized act within his official capacity and that defendant knew these facts. He argues that his conduct in not turning away from the officers did not amount to an actual obstruction to Stepien's traffic stop. Alternatively, defendant argues that the State failed to prove that defendant knew his actions would amount to an actual obstruction. We address each argument in turn.
¶ 17 In Baskerville , our supreme court stated that "[t]he legislative focus of section 31-1(a) is on the tendency of the conduct to interpose an obstacle that impedes or hinders the officer in the performance of his authorized duties." Baskerville , 2012 IL 111056, ¶ 23, 357 Ill.Dec. 500, 963 N.E.2d 898. Moreover, whether such an obstacle has been created is an inquiry reserved "for the trier of fact, based upon the facts and circumstances of each case." Id.
¶ 18 In his brief, defendant initially argues that his refusal to turn away from the officers "did not actually hamper or impede the officer's investigation of the traffic stop." Elsewhere, however, defendant concedes that "[a]t best, the State's evidence demonstrated that [defendant's] failure to turn around as instructed momentarily delayed the investigation." Further, defendant asserts on multiple occasions that his conduct caused only a "de minimis [sic ] delay" to Stepien's investigation. We interpret these as two distinct arguments: first, that defendant interposed no impediment or hinderance to Stepien's traffic stop and, second, that any such hinderance or impediment was so minor and brief that it fails to satisfy the requirements of section 31-1(a).
¶ 19 The first of these arguments need be addressed only briefly. The facts adduced at trial in this case leave no doubt that defendant's refusal to turn away from the officers as instructed impeded or hindered the traffic stop and gun investigation in some tangible way. While Stepien and Mitchem testified that the entire encounter involving defendant lasted less than three minutes, their testimony and reasonable inferences drawn therefrom make clear that defendant's conduct caused some delay in the investigation beyond the 20 seconds Mitchem would have expected that portion of the investigation to take. Under a strict interpretation of section 31-1(a), as explained in Baskerville , this delay, if only momentarily, hindered the investigation. We must therefore consider whether a de minimis exception applies to that statute.
¶ 21 In People v. Comage , 241 Ill. 2d 139, 150, 349 Ill.Dec. 119, 946 N.E.2d 313 (2011), the defendant was charged with obstruction of justice ( 720 ILCS 5/31-4 (West 2006) ) for throwing drug paraphernalia over a fence immediately prior to his arrest. The officers witnessed that act, walked around the fence, and were able to recover the items within 20 seconds. Comage , 241 Ill. 2d at 150, 349 Ill.Dec. 119, 946 N.E.2d 313. Our supreme court observed that in enacting the...
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