People v. Gallegos

After a bench trial, the defendant was convicted of driving under the influence of alcohol (625 ILCS 5/11 — 501 (West 1994)). On appeal, he contends that the 1995 amendment to section 1 — 6 of the Criminal Code of 1961 (720 ILCS 5/1 — 6 (West Supp. 1995)), which provides that the State is no longer required to prove venue at trial, is unconstitutional. He argues, therefore, that his conviction must be reversed because the State failed to prove venue beyond a reasonable doubt. We affirm.

FACTS

On December 17, 1995, Elk Grove Village police officer Frank Vrchota came upon the disabled vehicle of…