Illinois v. Espinoza
Annotate this CaseIn the summer of 2013, the State filed an information charging defendant Sandro Espinoza with domestic battery. The information stated that, “said defendant, knowingly, without legal justification made physical contact of an insulting or provoking nature with a minor, a family or household member, in that said defendant struck the minor about the face, in violation of Chapter 720, Section 5/12-3.2(a)(2), of the Illinois Compiled Statutes, 2012.” At Espinoza’s bond hearing, the State indicated that the victim was defendant’s son, who sustained a bloody nose. The trial court granted the State’s request for a no contact order, admonishing defendant that, as a condition of his bond, he was to have no contact with the minor, D.E. At a subsequent pretrial hearing, defense counsel indicted that Espinoza wanted to plead guilty and accept the State’s plea offer. However, defense counsel also noted his concern that there were no identifiers in the complaint, and orally moved to amend the charging instrument. The trial court declined to consider the oral motion, and directed defense counsel to file a written motion. The trial court also declined to accept Espinoza’s guilty plea to a complaint that was defective on its face. At issue in this case was whether the charging instrument, which identified the victim simply as “a minor,” was sufficient pursuant to section 111-3 of the Code of Criminal Procedure of 1963. In two separate criminal cases, the trial courts dismissed criminal complaints based upon the insufficiency of the charging instruments, where those charging instruments identified the victims only as “a minor.” The cases were consolidated on appeal. The appellate court, with one justice dissenting, affirmed. Finding no reason to disturb the appellate court's decision, the Supreme Court affirmed.
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