Illinois Supreme Court
People v. Galarza
February 2, 2023466 Ill. Dec. 1
Summary
The Illinois Supreme Court affirmed defendant's conviction for failure to reduce speed to avoid an accident, holding that the stipulated evidence supported findings that he drove carelessly and failed to reduce speed before colliding with a tree. The court also held that the stipulated bench trial was not tantamount to a guilty plea because defendant preserved a genuine factual defense that another person was driving, so Rule 402(a) admonishments were not required. The court further concluded that defendant forfeited the admonishment issue and could not establish clear or obvious error.