Background
Michael Riddle was charged after confronting Ashley Coleman at a Chicago gas station in December 2020. Coleman testified that Riddle demanded her keys, said he would shoot her, and reached into his pocket, leading her to believe he had a firearm. She fled, dropped her keys, and later backed away again when Riddle moved toward her SUV.
After retrieving the keys, Riddle appeared to approach the SUV but dropped them and left the immediate area. Following a bench trial, the circuit court acquitted him of attempted aggravated vehicular hijacking and aggravated robbery but, at Riddle’s request, considered and found him guilty of unlawful restraint as a lesser-included offense of aggravated robbery. It sentenced him to three years’ imprisonment.
The Court’s Holding
The Illinois Appellate Court affirmed. It held that the evidence was sufficient for a rational factfinder to conclude that Riddle knowingly and without legal authority detained Coleman, as required for unlawful restraint.
The court rejected Riddle’s argument that Coleman was not restrained because she could walk away and he never touched her. Physical force is not required, the court explained; the question is whether the defendant restricted the victim’s freedom to move. Riddle’s threats, apparent implication that he had a gun, demand for the keys, and conduct that caused Coleman to flee and remain away from her SUV supported the finding that her freedom of locomotion was impaired.
Key Takeaways
- Unlawful restraint can be established without physical contact or physical force.
- A threat implying possession of a firearm may restrain a victim by limiting the victim’s freedom to move.
- That a victim can create distance from an offender does not preclude a finding that the offender detained the victim.
Why It Matters
The decision underscores that unlawful restraint under Illinois law focuses on the practical restriction of a victim’s movement, not on whether the victim was physically held or entirely unable to leave. Threatening conduct that forces a victim away from a desired location or prevents access to property can satisfy that element.
The order was issued under Illinois Supreme Court Rule 23 and is nonprecedential except in the limited circumstances allowed by Rule 23(e)(1).