Sunday, November 17, 2013

People v. Grant case brief

People v. Grant case brief summary
360 N.E.2d 809 (1977)


CASE SYNOPSIS
Defendant appealed a judgment of the Circuit Court of Logan County (Illinois) that convicted him of aggravated battery and obstructing a police officer.

CASE FACTS
Third party was involved in an altercation with tavern owner. While third party was being arrested, defendant broke through the crowd and struck one police officer in the face. Defendant suffered a seizure in jail and was taken to the hospital. Defendant was charged with aggravated battery and obstructing a police officer. Defendant claimed he suffered from an epileptic seizure at the time of the alleged offenses.

DISCUSSION
  • The court held that the jury's finding of sanity was not against the manifest weight of the evidence because there was testimony that defendant was alert and in possession of his complete faculties at the time he was arrested. 
  • The jury instructions were substantially defective because they did not contain an instruction on the defense of involuntary conduct. 
  • The obstructing a police officer conviction was reversed because defendant could not be convicted for separate offenses that arose from the same course of conduct.
CONCLUSION
Judgment convicting defendant of battery and obstructing a police officer reversed because the jury instructions were substantially defective in that they did not include an instruction for the defense of involuntary conduct, and defendant could not be convicted for separate offenses that arose from the same course of conduct.

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