2024 IL App (4th) 230011 

NOS. 4-23-0011, 4-23-0012 cons. 

IN THE APPELLATE COURT

OF ILLINOIS

FOURTH DISTRICT

THE PEOPLE OF THE STATE OF ILLINOIS, 

Plaintiff-Appellee,

v. 

JAY K. BATES, 

Defendant-Appellant. 

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Appeal from the

Circuit Court of 

Woodford County 

Nos. 21CF93 

 22MT27 

Honorable 

Michael L. Stroh, 

Judge Presiding.

JUSTICE ZENOFF delivered the judgment of the court, with opinion. 

Justices Doherty and Lannerd concurred in the judgment and opinion. 

OPINION

¶ 1 Following a jury trial, defendant, Jay K. Bates, was convicted of aggravated fleeing 

or attempting to elude a peace officer (625 ILCS 5/11-204.1(a)(1) (West 2020)) and driving in 

excess of 35 miles per hour over the speed limit (id. § 11-601.5(b)). The Woodford County circuit

court sentenced defendant to 60 days in jail as to each conviction and 30 months and 24 months 

of probation, respectively. Defendant appeals, arguing the State presented insufficient evidence to 

support his conviction for aggravating fleeing or attempting to elude a peace officer. We affirm.

¶ 2 I. BACKGROUND

¶ 3 On July 1, 2021, the State charged defendant by indictment with aggravated fleeing 

or attempting to elude a peace officer (id. § 11-204.1(a)(1)) in that he was given a visual and/or 

audible signal by a peace officer to bring his vehicle to a stop, knowingly refused to obey such 

FILED

June 26, 2024

Carla Bender

4th District Appellate

Court, IL
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signal, and fled at a speed of at least 21 miles per hour over the speed limit (Woodford County 

case No. 21-CF-93). On January 25, 2022, the State also charged defendant by information with 

driving in excess of 35 miles per hour over the speed limit (id. § 11-601.5(b)) (Woodford County 

case No. 22-MT-27). 

¶ 4 On March 23, 2022, the cases proceeded to a joint jury trial. The State presented 

the testimonies of Deputy Cody Geick of the Woodford County Sheriff’s Office and Deputy Jared 

Meinart of the Livingston County Sheriff’s Office. 

¶ 5 Geick testified he was working patrol on the afternoon of June 18, 2021, in a 

marked patrol vehicle and wearing his uniform. He was driving on Route 116 behind a semitrailer 

when a motorcycle sped past him at a high rate of speed. The posted speed limit was 55 miles per 

hour. The motorcycle was orange, and the driver was wearing white shorts and a backpack. Geick 

activated his lights, which caused his dash camera to begin recording, and he turned on his siren.

He attempted to catch up to the motorcycle while driving 96 miles per hour. After a couple of 

minutes, he terminated his pursuit for safety reasons and noted his vehicle could not go as fast as 

the motorcycle. He advised dispatch to notify police in Livingston County the motorcycle was 

headed in their direction. He was later notified by dispatch the driver had been apprehended in 

Pontiac, Illinois, in Livingston County. He drove to the site and identified defendant as the person 

who was driving the motorcycle during his pursuit. He read defendant his Miranda rights. See 

Miranda v. Arizona, 384 U.S. 436 (1966). Defendant stated it was not him but then asked what the 

police could do for him, which Geick interpreted as, if defendant admitted to the crime, what could 

the police do for him in terms of the charges. 

¶ 6 Geick’s dash camera video was admitted into evidence. During the pursuit, the 

video showed a number of vehicles pulling over to allow Geick through. The video also displayed 
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different indicators for “mike, lights, brakes, and siren.” Geick explained his “mike pack” was not 

on his body at that time because it was charging but the indicator for “mike pack” would have been 

green if it was turned on. The indicator for “lights” was lit because his lights were on, and the 

indicator light turned off when he turned off his lights and ended his pursuit. The “siren” indicator 

was not lit, but the siren could be heard in the video. 

¶ 7 Meinart testified he was parked off the roadway in Flanagan, Illinois, in a marked 

sheriff’s vehicle. Dispatch advised him to be on the lookout for an orange motorcycle driven by a 

white male with a backpack. The motorcycle driver was reported to be driving in excess of 100 

miles per hour. Around 15 minutes later, he observed an orange motorcycle driving within a line 

of traffic at the speed limit. He pulled out and activated his lights, and the motorcycle took off. He 

pursued the motorcycle but then terminated his pursuit because he was driving 99 miles per hour 

and the motorcycle continued to pull away from him. He did not think it was safe to continue his

pursuit and noted his vehicle was capped at 105 miles per hour. He observed the motorcycle 

passing other traffic and notified dispatch he terminated his pursuit and lost sight of the motorcycle. 

He later learned the motorcycle driver was apprehended, went to the site, and verified defendant

was the same person who was driving the orange motorcycle. Meinart testified he told defendant 

he was the person he took off from, and defendant replied that he either did not know what Meinart 

was talking about or did not see Meinart. 

¶ 8 Defendant testified he lived in Merrillville, Indiana, and was driving his orange 

motorcycle in Illinois on the date in question as part of a memorial ride for his grandmother. He 

was wearing a helmet, which made it difficult to hear anything but the wind. He was listening to 

music using earbuds and had the volume turned all the way up, which was not typical for him, but

he was “drowning some sorrows.” He admitted to passing several vehicles; however, he neither 
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saw a police vehicle with its lights activated nor heard any sirens. He did not know how fast he 

was driving because he never looked and could not provide an estimation. He stated his motorcycle 

only had one mirror, and when he sat low when travelling at a high speed, he could only see the 

sky when he looked at the mirror. He stated he attentively watched the vehicles in front of him 

because he was concerned a vehicle would pull out in front of him while he was driving fast. He 

said he was driving fast because he was at “rock bottom” and explained that he lost his 

grandmother two years ago, he lost his father one year ago, his fiancée left him and took his dogs, 

and he lost a house. When defendant drove past Meinart while driving in a line of traffic, he nodded 

in Meinart’s direction as a show of respect. He took off once he approached the edge of town. He 

later exited the highway because he noticed his front tire was low on air and was then apprehended 

by police. He told police he merely drove a mile up the road, turned around, and came back. He 

admitted he lied to police but claimed he was in a state of duress because the police accused him 

of the instant charges. 

¶ 9 The State admitted photographs into evidence depicting the orange motorcycle 

seized by police; defendant in handcuffs; and Geick’s police vehicle, which demonstrated it was a

Ford Explorer, displayed a “sheriff” decal, and was equipped with a light bar on the roof. 

¶ 10 During closing arguments, the State argued defendant committed the crimes with 

respect to Geick’s pursuit of him in Woodford County. However, the State argued the jury should 

view Meinart’s observations and pursuit in Livingston County for credibility and as circumstantial 

evidence. Defendant argued the State’s evidence was insufficient and, specifically for the charge 

of aggravated fleeing and attempting to elude a peace officer, argued he did not act willfully 

because he did not know police officers were signaling for him to pull over.
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¶ 11 The jury found defendant guilty of both charges. The trial court sentenced 

defendant to 60 days in jail as to each conviction and 30 months of probation for aggravated fleeing 

or attempting to elude a peace officer and 24 months of probation for speeding. Defendant filed a 

motion to reconsider the sentence, which the court denied. 

¶ 12 This appeal followed.

¶ 13 II. ANALYSIS

¶ 14 On appeal, defendant argues the evidence presented was insufficient to support his 

conviction for aggravated fleeing or attempting to elude a peace officer. Specifically, he contends 

the State failed to prove (1) Geick’s police vehicle was equipped with and displayed illuminated 

oscillating, rotating, or flashing red or blue lights and (2) defendant acted willfully. The State 

maintains the evidence was sufficient to sustain the conviction. 

¶ 15 When reviewing a challenge to the sufficiency of the evidence, we view the 

evidence in the light most favorable to the prosecution and determine whether any rational trier of 

fact could have found each essential element of the crime beyond a reasonable doubt. People v. 

Carter, 2021 IL 125954, ¶ 42. The trier of fact, in this case the jury, “remains responsible for 

resolving conflicts in the testimony, weighing the evidence, and drawing reasonable inferences 

from the facts.” People v. Harris, 2018 IL 121932, ¶ 26. Thus, this court will not substitute our 

judgment for that of the trier of fact on questions pertaining to the weight of the evidence or 

credibility of witnesses. People v. Gray, 2017 IL 120958, ¶ 35. A criminal conviction will not be 

reversed unless the evidence is so unreasonable, improbable, or unsatisfactory that it creates a 

reasonable doubt of the defendant’s guilt. People v. Siguenza-Brito, 235 Ill. 2d 213, 225 (2009).

“This standard applies whether the evidence is direct or circumstantial, and circumstantial 
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evidence that meets this standard is sufficient to sustain a criminal conviction.” (Internal quotation 

marks omitted.) People v. Aljohani, 2022 IL 127037, ¶ 66. 

¶ 16 The Illinois Vehicle Code (Code) (625 ILCS 5/11-204(a) (West 2020)) defines 

fleeing or attempting to elude a peace officer as follows:

“Any driver or operator of a motor vehicle who, having been given a visual or 

audible signal by a peace officer directing such driver or operator to bring his 

vehicle to a stop, wilfully fails or refuses to obey such direction, increases his speed, 

extinguishes his lights, or otherwise flees or attempts to elude the officer, is guilty 

of a Class A misdemeanor. The signal given by the peace officer may be by hand, 

voice, siren, red or blue light. Provided, the officer giving such signal shall be in 

police uniform, and, if driving a vehicle, such vehicle shall display illuminated 

oscillating, rotating or flashing red or blue lights which when used in conjunction 

with an audible horn or siren would indicate the vehicle to be an official police 

vehicle.”

This offense is elevated to aggravated fleeing of attempting to elude a peace officer where such 

flight or attempt to elude “is at a rate of speed at least 21 miles per hour over the legal speed limit.” 

Id. § 11-204.1(a)(1). 

¶ 17 Here, Geick was in uniform and driving a police vehicle when he initiated his stop 

and pursued defendant. Defendant argues the State failed to prove Geick initiated the stop by 

displaying “illuminated oscillating, rotating, or flashing red or blue lights,” which was required by 

statute. The State admits it did not present evidence regarding the specifics of Geick’s lights but 

argues it could be reasonably inferred Geick’s lights satisfied this requirement. 
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¶ 18 In support of defendant’s argument, he primarily relies on People v. Murdock, 321 

Ill. App. 3d 175 (2001), and People v. Williams, 2015 IL App (1st) 133582. In Murdock, 321 Ill. 

App. 3d at 176, the defendant was charged with aggravated fleeing or attempting to elude a peace 

officer and argued the evidence was insufficient because no evidence showed the officer who

pursued him was in police uniform. The State argued the defendant should have known he was 

being pursued by a police officer based on the emergency lights and siren and that the purpose of 

the statute was nonetheless fulfilled. Id. at 177. The Appellate Court, Second District, agreed with 

the defendant and held the statutory requirement that the officer be in police uniform when

signaling a defendant to stop was an essential element of the offense, which the State failed to 

prove. Id.

¶ 19 In Williams, 2015 IL App (1st) 133582, ¶ 15, the defendant was also charged with

aggravated fleeing or attempting to elude a peace officer, but the officer testified he was in civilian 

clothing at the time of his pursuit. While relying on Murdock, the Appellate Court, First District, 

also found the State failed to prove an essential element of the offense, namely, that the officer 

was in police uniform. Id. The court similarly rejected the State’s argument that the defendant 

should have known he was being pursued by a police officer based on the use of lights and a siren 

and emphasized the question is not whether the defendant knew the police were following him but, 

rather, whether the essential elements of the statute had been met. Id. ¶ 16. 

¶ 20 Defendant argues the same rationale from Murdock and Williams applies to his case

because section 11-204(a) explicitly states the police officer shall be in uniform and similarly

explicitly states the police officer’s vehicle shall display illuminated oscillating, rotating, or 

flashing red or blue lights. See 625 ILCS 5/11-204(a) (West 2020). Therefore, he argues, because 

there was no evidence as to the specifics of the lights on Geick’s vehicle, his conviction cannot 
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stand. In reaching this conclusion, defendant acknowledges the cases relied on by the State favor

the opposite conclusion because they find this element may be inferred. See People v. Brown, 362 

Ill. App. 3d 374 (2005); People v. Hansen, 2019 IL App (3d) 170302. However, he simply 

contends these cases were wrongly decided.

¶ 21 In Brown, 362 Ill. App. 3d at 379, the defendant argued, as defendant argues here, 

the evidence was insufficient to support his conviction for aggravated fleeing or attempting to 

elude a peace officer because the officer failed to testify the emergency lights he activated were 

illuminated oscillating, rotating, or flashing red or blue lights as required by section 11-204(a) of 

the Code. The evidence demonstrated the officer was driving in a marked squad car and engaged 

the squad’s siren and emergency lights when he gave chase. Id. at 378-79. There was no evidence 

presented as to the specifics of the emergency lights, but the Appellate Court, First District, found 

it could be reasonably inferred that the officer activated his squad car’s illuminated oscillating, 

rotating, or flashing red or blue lights. The court explained the purpose of the lights and siren 

requirement is to indicate the pursuing vehicle to be an official police vehicle and, in the case 

before it, the officer clearly gave the defendant the statutorily required visual and audio signal to 

bring his vehicle to a stop. Id. at 379. 

¶ 22 In Hansen, 2019 IL App (3d) 170302, ¶ 14, the defendant presented the same 

argument before the Appellate Court, Third District. The officer testified his squad car’s 

emergency lights were illuminated during the pursuit, he was driving a marked squad car, and he 

was in uniform. Id. ¶ 16. Other vehicles pulled to the side of the road or stopped for the officer 

during his pursuit of the defendant, and it was evident the vehicles were not pulling over due to 

any reckless behavior on the part of the defendant. Id.The defendant also testified he saw the lights 

on the squad car, heard the siren, and recognized an officer was behind him. Id. At this point, the 
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court found “[t]he natural inference from this is that the vehicles pulled over because [the officer] 

activated his red and blue emergency lights.” Id. The court added that (1) the dash camera video 

from the perspective of another officer who had contact with the defendant during the incident 

showed his police vehicle’s lights were activated and were red and blue and (2) both officers 

worked for the same police department. Id. Therefore, following Brown, the court found the officer 

gave the defendant the requisite visual sign indicating he was driving an official police vehicle to 

satisfy section 11-204(a) of the Code. Id.

¶ 23 This is an issue of first impression for the Fourth District. The plain meaning of the 

statutory section at issue is that the initial signal to stop must involve the display of red or blue 

illuminated oscillating, rotating, or flashing lights. People v. Torrance, 2020 IL App (2d) 180246, 

¶ 16. As discussed, both Brown and Hansen found the purpose of requiring this specific display of 

lights in tandem with an audible horn or siren to provide notice to drivers that the vehicle 

attempting to effectuate a traffic stop is in fact an official police vehicle. Id. While Brown and 

Hansen seem to elevate compliance with the statutory purpose over the statute’s explicit 

requirement, we need not rely upon or even address such an approach. Here, the jury could have 

inferred compliance with the statutory requirements via circumstantial evidence. It is fundamental 

that the State need not present direct evidence of the light display, as it may satisfy this element

with circumstantial evidence that allows the trier of fact to infer the light display was proper. See 

People v. Toolate, 45 Ill. App. 3d 567, 569 (1976) (explaining an offense may be proven entirely 

by circumstantial evidence and there is no distinction in the law as to the legal weight of 

circumstantial evidence versus direct evidence); see also People v. Smith, 2014 IL App (1st) 

123094, ¶ 13 (“Circumstantial evidence is proof of facts and circumstances from which the trier 

of fact may infer other connected facts which reasonably and usually follow according to common 
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experience.” (Internal quotation marks omitted.)). We emphasize “it is the responsibility of the 

trier of fact to draw reasonable inferences from basic facts to ultimate facts” (Smith, 2014 IL App 

(1st) 123094, ¶ 13), and “the trier of fact is not required to disregard inferences which flow 

normally from the evidence and to search out all possible explanations consistent with innocence 

and raise them to a level of reasonable doubt” (internal quotation marks omitted) (People v. 

Wheeler, 226 Ill. 2d 92, 117 (2007)). 

¶ 24 In this case, we find the evidence of record satisfied the visual signal requirement

of section 11-204(a). Geick testified he turned on his vehicle’s lights when he began to pursue 

defendant. Further, when he turned on his lights, it activated his dash camera. His dash camera 

video was admitted into evidence. The vehicle’s indicator for “lights” was lit at this time and only 

turned off once Geick terminated his pursuit. While pursuing defendant, other vehicles redirected 

to the side of the road to allow the officer to pass through. Similar to Hansen, it was clear other 

drivers were responding to the officer’s signal instead of any reckless driving on behalf of 

defendant. We attach the photograph admitted into evidence of Geick’s police vehicle. 
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¶ 25 Geick’s police vehicle was a marked Ford Explorer equipped with a light bar on 

the roof, and in Illinois, this is a common patrol vehicle with red and blue emergency lights. We 

note that jurors’ common experience would unquestionably be influenced by the fact that the Code 

prohibits any vehicle other than police vehicles from displaying this configuration of lights. See 

625 ILCS 5/12-215(a)(1), (c)(3) (West 2020). The jurors were not required to abandon their 

common knowledge and experience at the door to the courthouse, as they “are supposed to be 

competent in everything pertaining to the ordinary and common knowledge of mankind.” Hays v. 

Place, 350 Ill. App. 504, 509 (1953). This approach is in keeping with the jury instruction given 

in this case, which directed the jury to “consider all the evidence in the light of [their] own 

observations and experience in life.” See Illinois Pattern Jury Instructions, Criminal, No. 1.01 (4th 

ed. 2000). 
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¶ 26 Based on the foregoing, the natural inference is that Geick had his red and blue 

emergency lights activated when he pursued defendant. See Hansen, 2019 IL App (3d) 170302,

¶ 16. The evidence clearly established Geick used the requisite visual and audio signals, which, 

when used together, indicated his vehicle was an official police vehicle. Therefore, we find the 

evidence sufficient to sustain defendant’s conviction on this basis. 

¶ 27 Defendant also argues the State failed to prove he willfully failed or refused to obey 

Geick’s direction because (1) he did not see police during the pursuits, (2) he was driving so fast 

that he was not paying attention to the cars he was passing, (3) he never heard a siren or saw lights 

as he was wearing a helmet, listening to his loud music, and traveling at a high rate of speed, (4) he 

only had one mirror on his motorcycle, (5) he could not utilize the mirror because he was hunkered 

down, and (6) he was focused on the road before him. The State argues the jury was free to reject 

defendant’s explanation of events and find him not credible, as the other evidence presented was 

sufficient to prove defendant was aware Geick’s police vehicle was behind him with its lights and 

siren activated seeking to pull him over. We agree with the State.

¶ 28 Whether defendant acted willfully came down to defendant’s credibility and the 

circumstantial evidence. See People v. Schofield, 2024 IL App (4th) 220961, ¶ 69 (stating a 

defendant’s mental state may be proved circumstantially by inferences reasonably drawn from the 

evidence, such as the defendant’s actions and circumstances surrounding the offense). Defendant 

testified on his own behalf that he was unaware of Geick’s pursuit, and the jury, as the trier of fact,

acted within its right to reject this explanation. See People v. Scott, 2018 IL App (2d) 151056, ¶ 28 

(“When a defendant elects to testify to explain inculpatory circumstances, the trier of fact may 

weight any inconsistencies or implausibilities in that testimony against the defendant.”).
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¶ 29 There is ample evidence of record to support the jury’s verdict. As previously noted, 

other vehicles responded to Geick’s signal as he pursued defendant. Defendant drove more than 

100 miles per hour for a significant distance while Geick pursued him with visual and audio 

signals, and despite Geick increasing his speed, defendant continued to pull away from him. See 

People v. Trump, 62 Ill. App. 3d 747, 749-50 (1978) (finding, where the officer followed the 

defendant for over a mile in a marked patrol car with lights and siren activated, the jury could 

reasonably infer that the defendant willfully attempted to elude the officer). Defendant admitted

to seeing Meinart, and the dash camera video showed defendant immediately took off at a high 

rate of speed after seeing him. Following two police pursuits, defendant appeared to only cease 

driving once he began experiencing issues with his front tire. At that time, defendant was 

apprehended by police and admittedly lied when he claimed he only drove up the road and back. 

See Schofield, 2024 IL App (4th) 220961, ¶ 73 (stating the defendant’s lie to police could fairly be 

viewed by the jury as his consciousness of guilt and, when considered with the surrounding 

circumstances of the offense, provided sufficient evidence for the jury to find the defendant guilty 

beyond a reasonable doubt). Although defendant denied the instant charges, he seemingly asked 

Geick what the police could do for him if he admitted to the crime.

¶ 30 While drawing all reasonable inferences in favor of the prosecution, we conclude 

any rational trier of fact could have found defendant acted willfully beyond a reasonable doubt. 

Therefore, the evidence was sufficient to sustain defendant’s conviction for aggravated fleeing or 

attempting to elude a peace officer.

¶ 31 III. CONCLUSION

¶ 32 For the reasons stated, we affirm the trial court’s judgment. 

¶ 33 Affirmed.
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People v. Bates, 2024 IL App (4th) 230011 

Decision Under Review: Appeal from the Circuit Court of Woodford County, Nos. 21-

CF-93, 22-MT-27; the Hon. Michael L. Stroh, Judge, presiding.

Attorneys

for 

Appellant:

James E. Chadd, Douglas R. Hoff, and Daniel T. Mallon, of 

State Appellate Defender’s Office, of Chicago, for appellant.

Attorneys

for 

Appellee:

Gregory Minger, State’s Attorney, of Eureka (Patrick Delfino 

and Thomas D. Arado, of State’s Attorneys Appellate 

Prosecutor’s Office, of counsel), for the People.