People v. Prince
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Romeoville police responded to a call that a residential security alarm had been activated. Prince came to the door and stated “Jessica” lived there but was out of town. He refused to give his name or identification. Prince was arrested and taken to the police station. Another officer remained at the residence, spoke to a friend of Jessica’s, and obtained Prince’s social media username. From this, the officer determined Prince’s name and learned there was an active warrant out for his arrest. The warrant had been issued in error and was later vacated. Prince initially refused to be fingerprinted or to take a booking photo, stating his name was “Sean Williams” and giving an incorrect birth date. Prince agreed to allow the police to fingerprint and photograph him “more than minutes,” after arriving at the station.
At trial, the parties did not raise, and the court did not address “material impediment” as an element of obstruction of justice by furnishing false information (720 ILCS 5/31-4(a)(1). A jury convicted Prince. On appeal, the state conceded that the evidence presented was insufficient as a matter of law where the state offered no evidence on the “material impediment” element. The appellate court remanded for a new trial, finding double jeopardy did not bar retrial. The Illinois Supreme Court reversed. Retrial is prohibited. There was no trial error, or anything similar, that prevented the state—which bore the burden of proof—from introducing evidence on the issue of material impediment.
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