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8 Illinois opinions name it 2 courts 2020–2025 7 in the last five years
The cases below were cited by Illinois courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.
| Case | Followed | Cited |
|---|---|---|
People v. Mehtagreen2 sentences2025See People v. Gotschall, 2022 IL App (4th) 210256, ¶ 26 (“[T]he offense of obstructing a peace officer set forth in section 31- 1(a) of the [Criminal] Code includes a material impediment requirement.”); Mehta, 2020 IL App (3d) 180020, ¶ 26 (“[O]bstruction of a peace officer is committed only where a defendant’s conduct creates an obstacle that materially impedes or hinders the officer in the performance of his authorized duties.” (Internal quotation marks omitted.)). 2023See People v. Gotschall, 2022 IL App (4th) 210256, ¶ 27 (“In the context of the offense of obstructing a peace officer, the supreme court decisions in Comage, Baskerville, and Casler, taken together, lead us to conclude that the material impediment requirement set forth in Baskerville should logically apply to any obstructive conduct alleged to have hindered or impeded authorized acts of peace officers in violation of [section 31-1(a)].”); People v. Mehta, 2020 IL App (3d) 180020, ¶ 26 (“We *** hold that obstruction of a peace officer is committed only where a defendant’s conduct creates an ob | 3 | 3 |
People v. Gotschallgreen2 sentences2025See People v. Gotschall, 2022 IL App (4th) 210256, ¶ 26 (“[T]he offense of obstructing a peace officer set forth in section 31- 1(a) of the [Criminal] Code includes a material impediment requirement.”); Mehta, 2020 IL App (3d) 180020, ¶ 26 (“[O]bstruction of a peace officer is committed only where a defendant’s conduct creates an obstacle that materially impedes or hinders the officer in the performance of his authorized duties.” (Internal quotation marks omitted.)). 2023See People v. Gotschall, 2022 IL App (4th) 210256, ¶ 27 (“In the context of the offense of obstructing a peace officer, the supreme court decisions in Comage, Baskerville, and Casler, taken together, lead us to conclude that the material impediment requirement set forth in Baskerville should logically apply to any obstructive conduct alleged to have hindered or impeded authorized acts of peace officers in violation of [section 31-1(a)].”); People v. Mehta, 2020 IL App (3d) 180020, ¶ 26 (“We *** hold that obstruction of a peace officer is committed only where a defendant’s conduct creates an ob | 2 | 3 |
People v. Sadder-Beygreen2 sentences2025While they are two separate prohibitions, the crime of obstructing or resisting a peace officer ‘addresses related types of interference.’ ” Sadder-Bey, 2023 IL App (1st) 190027, ¶ 39 . 2023See People v. Gotschall, 2022 IL App (4th) 210256, ¶ 27 (“In the context of the offense of obstructing a peace officer, the supreme court decisions in Comage, Baskerville, and Casler, taken together, lead us to conclude that the material impediment requirement set forth in Baskerville should logically apply to any obstructive conduct alleged to have hindered or impeded authorized acts of peace officers in violation of [section 31-1(a)].”); People v. Mehta, 2020 IL App (3d) 180020, ¶ 26 (“We *** hold that obstruction of a peace officer is committed only where a defendant’s conduct creates an ob | 1 | 2 |
People v. Comagegreen2 sentences2023See People v. Comage, 241 Ill. 2d 139, 150 (2011) (stating that, within the context of the obstructing justice statute, “a defendant who places evidence out of sight during an arrest or pursuit has ‘concealed’ the evidence *** if, in doing so, the defendant actually interferes with the administration of justice, i.e., materially impedes the police officers’ investigation”). ¶ 63 Allowing all reasonable inferences from the record in favor of the State, as we must in a challenge to the sufficiency of the evidence, the evidence was sufficient to sustain defendant’s conviction for obstructing iden 2022Comage, 241 Ill. 2d at 143 . | 1 | 2 |
People v. Schronskigreen1 sentence2023See People v. Schronski, 2014 IL App (3d) 120574, ¶ 23 (detained defendant providing a false name to authorities completes the offense). ¶ 62 We need not decide whether the obstructing identification statute includes a material impediment requirement because, even if it contains such a requirement, we would find that the evidence adduced at trial was sufficient to prove defendant guilty beyond a reasonable doubt. | 1 | 1 |
United States v. Arturo Gonzalez and Ricardo Ramirezgreen1 sentence2020See United States v. Pearl, 324 F.3d 1210, 1214 (10th Cir. 2003); United States v. Gonzalez, 93 F.3d 311, 323 (7th Cir. 1996) (citing Wacker, 72 F.3d at 1465 ); Weems, 49 F.3d at 531 . ¶ 66 More fundamentally, the error that manifested at defendant’s trial is, despite the nomenclature employed by the parties, more akin to trial error than to the sufficiency of the evidence. | 1 | 1 |
United States v. Pearlgreen1 sentence2020See United States v. Pearl, 324 F.3d 1210, 1214 (10th Cir. 2003); United States v. Gonzalez, 93 F.3d 311, 323 (7th Cir. 1996) (citing Wacker, 72 F.3d at 1465 ); Weems, 49 F.3d at 531 . ¶ 66 More fundamentally, the error that manifested at defendant’s trial is, despite the nomenclature employed by the parties, more akin to trial error than to the sufficiency of the evidence. | 1 | 1 |
People v. Andrew B.green1 sentence2020See In re Andrew B., 237 Ill. 2d 340, 352 (2010) (recognizing “the fundamental principle of statutory construction that this court cannot read into the statute additional elements not intended by the legislature”) ¶ 78 The majority here, however, discerns a material impediment requirement after reviewing dictionary definitions and synonyms of the word “furnish” (supra ¶¶ 29- 30) and concluding that those sources demonstrate a “clear denotation of necessity” (supra ¶ 30). | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Illinois. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
People v. Casler
green
2 sentences2023We therefore reverse defendant’s conviction and vacate his sentence. ¶ 28 In an effort to provide clear guidance for future cases, we acknowledge that this holding could be read to conflict with the following discussion in Casler: “We determine that the evidence was sufficient under the instruction that was given, rather than the instruction that would otherwise be given on remand. [Citations.] Here, the State had no reason to introduce evidence regarding a material impediment requirement because, at the time of trial, this court had not yet held that the government was required to prove that 2022Moreover, the supreme court clarified in Casler that it had held in Baskerville that “furnishing false information may constitute obstructing a peace officer when a material impediment is established.” Casler, 2020 IL 125117, ¶ 40 . ¶ 27 While Baskerville involved the obstructive conduct of providing false information to a police officer, the Casler court held, in the related context of the obstructing justice statute, that the material impediment requirement applied to all the obstructive conduct set forth in - 10 - section 31-4(a) of the Code and was not limited to the “concealment clause” a | 2 | 2022–2023 |
People v. Taylor
green
1 sentence2022The court approvingly cited People v. Taylor, 2012 IL App (2d) 110222 , which interpreted Comage as incorporating a material impediment requirement into the entire obstructing justice statute. | 1 | 2022–2022 |
United States v. Clarke Dexter Weems
green
1 sentence2020See United States v. Pearl, 324 F.3d 1210, 1214 (10th Cir. 2003); United States v. Gonzalez, 93 F.3d 311, 323 (7th Cir. 1996) (citing Wacker, 72 F.3d at 1465 ); Weems, 49 F.3d at 531 . ¶ 66 More fundamentally, the error that manifested at defendant’s trial is, despite the nomenclature employed by the parties, more akin to trial error than to the sufficiency of the evidence. | 1 | 2020–2020 |
cluster 710261
green
1 sentence2020See United States v. Pearl, 324 F.3d 1210, 1214 (10th Cir. 2003); United States v. Gonzalez, 93 F.3d 311, 323 (7th Cir. 1996) (citing Wacker, 72 F.3d at 1465 ); Weems, 49 F.3d at 531 . ¶ 66 More fundamentally, the error that manifested at defendant’s trial is, despite the nomenclature employed by the parties, more akin to trial error than to the sufficiency of the evidence. | 1 | 2020–2020 |
People v. McKown
green
1 sentence2020McKown, 236 Ill. 2d at 311 . ¶ 61 In the case at bar, we unequivocally construe section 31-4(a)(1) of the Criminal Code to include a material impediment requirement. | 1 | 2020–2020 |
People v. Casler
green
1 sentence2020The appellate court maintained that the Comage court limited its recognition of a material impediment requirement to the concealment clause of section 31-4(a) of the Criminal Code. 2019 IL App (5th) 160035 , ¶¶ 41, 45. | 1 | 2020–2020 |
Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.
Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.