In People v. Coates, the Illinois Appellate Court affirmed the conviction of Aswad J. Coates for two counts of obstructing a peace officer following a contentious traffic stop during which Coates identified himself as a “sovereign citizen” and refused to comply with standard police commands. The decision clarifies the threshold for obstruction in the context of routine traffic stops, especially when refusal to comply is coupled with rhetoric from the sovereign citizen movement.
The case arose from a September 2022 traffic stop in Lincoln, Illinois. Corporal Collin Antoine pulled over Coates for speeding. Coates questioned the legality of the stop, cited sovereign citizen talking points, and refused to provide identification or exit his vehicle. Antoine called for backup, and officers physically removed Coates from the car. A dashcam video confirmed that Coates repeatedly cited legal theories asserting a right to “freedom of travel” and demanded articulation of a “crime” before cooperating.
Coates was charged with obstructing a peace officer for (1) failing to provide identification and (2) refusing to exit his vehicle. A jury convicted him on both obstruction counts but acquitted him of resisting arrest and two additional charges.
On appeal, Coates argued that the evidence was insufficient because the State failed to prove he had caused a material impediment to law enforcement duties—a requirement under Illinois law. He also claimed the jury instructions were defective for not explicitly including this “material impediment” requirement.
The appellate court disagreed. First, it distinguished this case from People v. Sadder-Bey, in which a sovereign citizen defendant’s polite, noncompliant conduct during a daytime traffic stop was deemed insufficient for a resisting conviction. Unlike Sadder-Bey, Coates was charged with obstruction, not resistance. The court emphasized that obstruction requires a material hindrance to an officer’s authorized act, and found that Coates’ persistent five-minute refusal to provide ID—despite repeated lawful requests—delayed the stop and necessitated backup. Though the delay was relatively brief, it occurred at night and on a parkway with part of the car in a traffic lane, elevating safety concerns. The court held that a reasonable juror could find this delay to be a material impediment.
As to the second conviction, the court reaffirmed that police may order drivers out of a vehicle during a lawful stop for officer safety. Coates was told multiple times to exit before officers forcibly removed him. The court found this refusal posed a potential safety threat and, under precedent (People v. Mehta, Synnott), any delay that jeopardizes officer safety may support an obstruction conviction.
The appellate court also rejected Coates’ argument regarding jury instructions. While it agreed the materiality requirement is a necessary component of obstruction, it found that the standard pattern instruction given—requiring the jury to find that the defendant obstructed a peace officer performing an authorized act—adequately conveyed that requirement. The materiality element, the court explained, is embedded in the statutory definition of obstruction and does not require a separate instruction.
Coates was sentenced to 12 months’ probation and 100 hours of community service.
Source: People v. Coates, 2025 IL App (4th) 231312