People v. Johnson

In 2001, Darren Johnson (defendant) hit Denise Howard with his car after an altercation. Howard was launched onto the car and Johnson drove the car about 15 feet before Howard fell off. Johnson drove away. When police arrived on the scene, Howard stated that Johnson was her boyfriend. The State of Illinois (plaintiff) charged Johnson with aggravated battery and aggravated domestic battery, which criminalizes committing aggravated battery of an individual with whom the perpetrator has a dating relationship. At trial, Johnson testified that Howard was his girlfriend, that they had been together for about one year, and that they had plans to get married. Johnson also testified that Howard had visited him while he was in jail awaiting the trial and that he had written love letters to Howard. Howard also testified as to the nature of her relationship with Johnson, and she reiterated much of what Johnson had stated. Following the trial, Johnson was found guilty of both offenses and the aggravated battery was merged into the aggregated-domestic-battery offense. Johnson appealed his conviction on the ground that the aggravated-domestic-battery offense was unconstitutional because the phrase dating relationship was unconstitutionally vague. As evidence, Johnson alleged that the trial court had been confused as to the nature of Howard and Johnson’s relationship because of the contents of the letters he sent to Howard.