People v. Fowler

── People v. Fowler ── Court: Appellate Court of Illinois Date: April 14, 2026 Category: General NOTICE: This order was filed under Illinois Supreme Court Rule 23 and is not precedent except in the limited circumstances allowed under Rule 23(e)(1). 2026 IL App (3d) 240584-U Order filed April 14, 2026 ____________________________________________________________________________ IN THE APPELLATE COURT OF ILLINOIS THIRD DISTRICT 2026 THE PEOPLE OF THE STATE OF ) Appeal from the Circuit Court ILLINOIS, ) of the 18th Judicial Circuit, ) Du Page County, Illinois, Plaintiff-Appellee, ) ) Appeal No. 3-24-0584 v. ) Circuit No. 23-CM-839 ) KARI L. FOWLER, ) Honorable ) Paul A. Marchese, Defendant-Appellant. ) Judge, Presiding. ____________________________________________________________________________ JUSTICE PETERSON delivered the judgment of the court. Presiding Justice Hettel and Justice Brennan concurred in the judgment. ____________________________________________________________________________ ORDER ¶1 Held: (1) The stalking no contact order was valid as the issuing court had personal jurisdiction over defendant. (2) The admission of written jury instructions that were not modified to accurately reflect the applicable law was harmless error. ¶2 Defendant, Kari L. Fowler, appeals her conviction for violating an emergency stalking no contact order (SNCO), arguing that the underlying order was invalid for lack of jurisdiction and was not authorized by statute. Defendant further contends that the Du Page County circuit court erred by omitting essential elements of the charged offense from the jury instructions. We affirm. ¶3 I. BACKGROUND ¶4 The State charged defendant with violating an SNCO (720 ILCS 5/12-3.9(a) (West 2022)). The State alleged that defendant knowingly committed an act prohibited by an SNCO when she entered or remained at 1809 W. Diehl Road in Naperville on May 23, 2023. The case proceeded to a jury trial on July 9, 2024. 1 ¶5 The evidence at trial established that Yolanda Gill had obtained an ex parte emergency SNCO against defendant on May 22, 2023. The State introduced a certified copy of the order. The order was issued without prior notice to defendant and prohibited her from entering or remaining at Gill’s place of employment, a hotel located at 1809 W. Diehl Road in Naperville. The order indicated that defendant resided at the same address. ¶6 The next morning, Gill called 911 after she saw defendant in the lobby of the hotel. After the police arrived at the hotel, an officer advised defendant that Gill had obtained an SNCO against her. The officer informed defendant that she would be subject to arrest for violating the order if she did not leave the premises and attempted to serve her with the SNCO via short form notification. Defendant told the officer that she resided at the hotel, refused to take possession of the notification paperwork, and proceeded to enter an elevator located on the main floor. ¶7 After the State presented