People v. Cihak

Defendant, Wayne Cihak, was charged with using a fictitious name and making a materially false statement on an Illinois application for a certificate of car title. The trial court found defendant guilty. Defendant appeals contending that the court erred in admitting evidence of defendant’s prearrest silence and that he was not proven guilty beyond a reasonable doubt.

On December 19, 1984, Chicago police officer John Miller arrested defendant for knowingly permitting “another to register a vehicle with a fictitious name and address with the Illinois Secretary of State.” Defendant’s information…