Justia Illinois Supreme Court Opinion Summaries

The defendant was charged with attempted first degree murder and aggravated battery with a firearm after a shooting incident in which the victim, Bell, was shot in the head while sitting in the passenger seat of a vehicle outside the defendant’s residence. The evidence at trial included testimony from police officers, medical personnel, neighbors, and the defendant’s wife, as well as the defendant’s own statements to police and a recorded jail call. The defendant initially denied involvement but later admitted to shooting Bell, claiming it was accidental. After the State rested its case, the defense moved for a directed verdict, but the trial court reserved its ruling and proceeded to the defense’s case without deciding the motion. The defense ultimately rested without presenting evidence, and the jury found the defendant guilty.The Circuit Court of Rock Island County denied the defendant’s posttrial motion, which argued that the court’s failure to rule on the directed verdict motion prejudiced his right to a fair trial. The court merged the convictions and sentenced the defendant to 50 years for attempted first degree murder. On appeal, the Appellate Court of Illinois, Fourth District, affirmed the conviction and sentence, finding the evidence sufficient and holding that the defendant had forfeited review of the directed verdict issue by failing to object at trial. The appellate court also found no clear or obvious error for purposes of plain error review due to unsettled law on the timing of such rulings.The Supreme Court of Illinois reviewed whether a trial court must decide a defendant’s midtrial motion for a directed verdict before proceeding to the defense’s evidence. The court held that section 115-4(k) of the Code of Criminal Procedure requires the trial court to decide a midtrial motion for a directed verdict before advancing to the defense’s case. However, the court found that the error in this case did not warrant reversal under the plain error rule because the evidence was not closely balanced and the defendant failed to establish second prong plain error. The court affirmed the judgments of the appellate and circuit courts. View "People v. Johnson" on Justia Law

The case concerns an individual who, in 2003, was charged with four counts of aggravated unlawful use of a weapon (AUUW) in Illinois. Two counts were for carrying a loaded, uncased firearm in public, and two were for carrying a firearm without a valid Firearm Owner’s Identification (FOID) card. Pursuant to a negotiated plea agreement, the defendant pleaded guilty to one count, and the State agreed to dismiss the remaining three counts. He was sentenced to probation, later resentenced to prison after violating probation, and ultimately served time.Years later, the Illinois Supreme Court in People v. Aguilar found the statute under which the defendant was convicted to be unconstitutional. The defendant’s conviction was vacated, and he then sought a certificate of innocence (COI) under Illinois law, which would allow him to seek compensation for wrongful imprisonment. The Cook County Circuit Court denied the COI, reasoning that the statute required the petitioner to prove innocence of all offenses charged in the information, not just the one for which he was convicted and incarcerated. The court found the petitioner could not prove innocence on the counts related to possession without a FOID card, as that conduct remained illegal.The Illinois Appellate Court affirmed, holding that the COI statute required proof of innocence for all charges in the charging instrument, including those dismissed as part of the plea agreement. The Supreme Court of Illinois reviewed the case and affirmed the appellate court’s judgment. The court held that, under the COI statute, a petitioner must prove innocence of every offense charged in the information, including those nol-prossed as part of a plea agreement, not just the offense for which the petitioner was incarcerated. Because the petitioner could not prove innocence of all charges, he was not entitled to a COI. View "People v. Reed" on Justia Law

Matthew Smith was charged with first degree murder following a shooting outside the Press Box bar in August 2012. Multiple eyewitnesses identified Smith as the shooter, both in police lineups and at trial. The lineups included fillers who differed from Smith in age and hairstyle, and in the second lineup, Smith wore a distinctive red and white shirt that witnesses had described the shooter as wearing. Physical evidence included shell casings and a revolver found in a vehicle from which Smith fled, as well as a photograph of Smith in the bar wearing the same shirt. Smith’s mother was excluded from the courtroom during parts of the trial because she was listed as a potential witness.The Cook County Circuit Court denied Smith’s motions to suppress the lineup identifications and to exclude the photograph, and after a jury trial, Smith was convicted and sentenced to 30 years in prison. On appeal, the Illinois Appellate Court reversed the conviction and remanded for a new trial, finding that excluding Smith’s mother violated his right to a public trial. The appellate court also found errors regarding the suggestiveness of the second lineup, a discovery violation in the gunshot residue expert’s testimony, improper closing arguments by the prosecution, and error in sending the photograph to the jury.The Supreme Court of Illinois reviewed the case and held that excluding Smith’s mother did not violate his right to a public trial, as the courtroom remained open to other family members, spectators, and the media. The court further found that the second lineup was not unduly suggestive, the discovery violation regarding the gunshot residue expert did not warrant reversal, the trial court did not abuse its discretion in allowing the jury to view the photograph, and the challenged prosecutorial comments did not constitute reversible error. The Supreme Court reversed the appellate court’s judgment, affirmed the conviction, and remanded for consideration of any remaining unresolved issues. View "People v. Smith" on Justia Law

A defendant was convicted by a jury in Boone County, Illinois, of driving while his license was revoked. He had two prior convictions for the same offense. Under the Illinois Vehicle Code, a third or subsequent conviction for this offense requires the court to impose either a minimum term of 30 days’ imprisonment or 300 hours of community service, as determined by the court. The County Jail Good Behavior Allowance Act further provides that a defendant sentenced for an offense with a mandatory minimum sentence cannot receive good-behavior credit that would reduce the sentence below that minimum.The Circuit Court of Boone County, presided over by Judge Robert Tobin, sentenced the defendant to 14 days in jail, with day-for-day credit for good behavior. The judge reasoned that because the statute allowed for community service as an alternative, it did not establish a mandatory minimum jail term, and thus a shorter jail sentence with good-behavior credit was permissible.The State’s Attorney of Boone County sought a writ of mandamus from the Supreme Court of the State of Illinois, arguing that the circuit court’s sentence did not comply with the statutory requirements. The Supreme Court of the State of Illinois reviewed the statutory language de novo and found it unambiguous. The court held that when the circuit court chooses imprisonment rather than community service, the Vehicle Code requires a minimum of 30 days in jail, and the Behavior Act prohibits any good-behavior credit that would reduce the sentence below that minimum.The Supreme Court of the State of Illinois vacated the circuit court’s sentencing order and issued a writ of mandamus, directing the circuit court to resentence the defendant in compliance with the Vehicle Code and the Behavior Act. The court clarified that the statutes set a mandatory minimum sentence when imprisonment is chosen, and good-behavior credit cannot reduce the sentence below that minimum. View "People ex rel Smith v. Tobin" on Justia Law

A defendant was charged with possession of a stolen motor vehicle, a Class 2 felony, after allegedly taking a vehicle from a relative without permission. Following her arrest, she was released with conditions but repeatedly failed to appear for scheduled court dates, resulting in multiple arrest warrants and brief periods of detention. The State ultimately filed a petition for sanctions due to her repeated absences, but did not file a petition seeking her pretrial detention under the Pretrial Fairness Act. The defendant’s absences were sometimes explained by hospitalization, though she did not always provide documentation.The case was heard in the Circuit Court of Cook County, where the presiding judge declared the Pretrial Fairness Act unconstitutional as applied to the defendant. The judge asserted an inherent judicial authority to detain defendants indefinitely pretrial, arguing that the Act’s limitations on judicial discretion violated the separation of powers clause of the Illinois Constitution. The judge ordered the defendant detained until trial, despite statutory provisions limiting detention to a 30-day sanction period for failure to appear and requiring a State petition for further detention. The defendant’s motion to reconsider was denied, and she sought appellate relief, including habeas corpus, mandamus, and supervisory orders.The Supreme Court of Illinois reviewed the case after transfer from the appellate court and consolidation of related proceedings. The court held that the Pretrial Fairness Act does not violate the separation of powers clause as applied to this case. It found that the circuit court lacked authority to detain the defendant indefinitely without a statutory basis and that the Act’s procedures for pretrial release and sanctions do not unduly infringe on judicial powers. The Supreme Court reversed the circuit court’s judgment, granted habeas corpus relief, and ordered the defendant’s immediate release. View "Stewart v. Rosenblum" on Justia Law

Two police officers employed by a city were injured in separate incidents while on duty. After their injuries, both received payments from the city under section 1(b) of the Illinois Public Employee Disability Act, which provides that eligible employees unable to work due to a duty-related injury must continue to be paid “on the same basis” as before the injury, without deductions from sick leave, compensatory time, or vacation. The city continued to pay their salaries as before, including withholding federal and state income taxes, Social Security, and Medicare taxes. The officers filed suit, alleging that the city violated the Disability Act by withholding employment taxes and, for one officer, by deducting accrued leave time.The Circuit Court of Tazewell County granted summary judgment for the officers, finding that section 1(b) prohibited the withholding of employment taxes and required payment of “gross pay.” The court also found the city had improperly deducted leave time and held that the ten-year statute of limitations for breach of contract applied, awarding damages and fees to the plaintiffs. On appeal, the Illinois Appellate Court, Fourth District, reversed, holding that section 1(b) does not prohibit withholding employment taxes, and that the five-year statute of limitations applied. The appellate court also found a genuine issue of fact regarding whether leave time was improperly deducted and remanded for further proceedings.The Supreme Court of Illinois reviewed the case and affirmed the appellate court’s judgment. The court held that section 1(b) of the Disability Act does not prohibit a public employer from withholding employment taxes from payments made to an injured employee under that provision. The court reasoned that the statute’s language requires payment “on the same basis” as before the injury, which includes continued tax withholding, and expressly prohibits only certain deductions, not taxes. The case was remanded for further proceedings on the leave time deduction claim. View "Bitner v. City of Pekin" on Justia Law

The case concerns a defendant who was in a romantic relationship with the victim, Barbara Rose, and lived with her and her children in Danville, Illinois. In October 2017, Rose disappeared, and her body was later found dismembered and burned. Evidence at trial included testimony from acquaintances, video surveillance showing the defendant purchasing items such as gasoline and plastic, forensic evidence linking the defendant to the crime scene and the victim’s remains, and statements made by the defendant to a jail informant. The defendant was charged in three separate Vermilion County cases with first degree murder, multiple counts of concealment of a homicidal death, and multiple counts of dismembering a human body, all relating to acts taken to conceal and dismember Rose’s body at different times and locations.After a jury trial, the defendant was convicted on all counts and sentenced to consecutive terms totaling 94 years. The Circuit Court of Vermilion County denied posttrial motions, including claims of ineffective assistance of counsel and arguments that the multiple convictions for concealment and dismemberment were improper. On appeal, the Illinois Appellate Court, Fourth District, affirmed the convictions and sentences, holding that the evidence was sufficient, counsel was not ineffective, and multiple convictions were proper because the acts occurred on separate dates and involved discrete conduct.The Supreme Court of the State of Illinois reviewed the case. It held that the defendant’s trial counsel was not ineffective, as there was no reasonable probability that the outcome would have been different even if counsel had acted as the defendant argued. However, the court found that the statutes for concealment of a homicidal death and dismemberment of a human body do not authorize multiple convictions for acts taken as part of the same course of conduct to conceal the same death or dismember the same body. Accordingly, the court affirmed the murder conviction, but reversed and vacated one dismemberment conviction and two concealment convictions, leaving only one conviction for each of those offenses. View "People v. Keys" on Justia Law

A licensed clinical therapist and his employer provided substance abuse rehabilitation services to a physician whose medical license had been suspended. When the physician later sought reinstatement of his license, the Illinois Department of Financial and Professional Regulation requested the therapist’s personal notes from the rehabilitation program as part of the administrative proceedings. The therapist and his employer refused, asserting that the notes were protected under the Mental Health and Developmental Disabilities Confidentiality Act. They sought a protective order in the Circuit Court of Cook County to prevent disclosure of the notes.The circuit court conducted an in camera review and agreed that the notes were protected, issuing a protective order barring the Department from obtaining them. The court also awarded the plaintiffs attorney fees and costs under section 15 of the Confidentiality Act. The Department did not challenge the protective order but appealed the award of attorney fees and costs, arguing that such an award was barred by sovereign immunity. The Appellate Court of Illinois affirmed the circuit court’s award, holding that the fees and costs were ancillary to the injunctive relief and thus not barred by sovereign immunity.The Supreme Court of the State of Illinois reviewed the case to determine whether the circuit court had subject-matter jurisdiction to award attorney fees and costs against the Department. The court held that, absent an explicit statutory waiver of sovereign immunity, Illinois courts lack jurisdiction to enter monetary judgments against the State for attorney fees and costs. The court found that section 15 of the Confidentiality Act does not contain such a waiver. Therefore, the Supreme Court reversed the appellate court’s judgment and the portion of the circuit court’s judgment awarding attorney fees and costs, but did not disturb the protective order itself. View "Lavery v. Department of Financial and Professional Regulation" on Justia Law

The case concerns a petitioner who was convicted of first degree murder and aggravated discharge of a firearm following a bench trial in the Circuit Court of Cook County. The incident involved a drive-by shooting in which the victim was killed, and the petitioner, a member of the Satan Disciples gang, was accused of firing the shots. The prosecution presented eyewitness testimony and police evidence, while the petitioner maintained his innocence, claiming he was at home with family at the time of the shooting. The trial court found the petitioner guilty and imposed a lengthy prison sentence.After his conviction was affirmed on direct appeal by the Appellate Court of Illinois, First District, and further review was denied by both the Illinois Supreme Court and the United States Supreme Court, the petitioner pursued postconviction relief. He filed multiple postconviction petitions alleging ineffective assistance of counsel and actual innocence, supported by affidavits from family members and other witnesses. The circuit court dismissed these petitions, finding the claims either waived, not credible, or insufficient under the applicable legal standards. The appellate court later reversed the dismissal of a successive postconviction petition, finding a substantial showing of actual innocence and remanded for a third-stage evidentiary hearing. Importantly, the appellate court ordered, sua sponte, that the case be assigned to a different judge on remand, citing interests of justice and concerns about the prior judge’s handling of the case.The Supreme Court of Illinois reviewed whether the appellate court had authority to order reassignment to a new judge on remand for reasons other than bias, potential bias, or prejudice. The court held that, in postconviction proceedings, an appellate court may only order reassignment to a new judge sua sponte if the record clearly reveals bias, the probability of bias, or prejudice by the trial judge. The court found no such circumstances in this case and reversed the appellate court’s order for reassignment, affirming in part and reversing in part, and remanded the cause to the circuit court. View "People v. Class" on Justia Law

Abdul Malik Muhammad was convicted of first-degree murder in 2001 for the 1999 shooting death of Damone Mims. Muhammad was interrogated by Chicago police detectives and allegedly made incriminating statements, which he later denied. He was sentenced to 50 years in prison. Muhammad's conviction and sentence were affirmed on direct appeal, and his subsequent postconviction petition and habeas corpus petition were denied.Muhammad later filed a claim with the Illinois Torture Inquiry and Relief Commission (TIRC), alleging he was tortured by police during his interrogation. The TIRC found sufficient evidence of torture to merit judicial review and referred the case to the Cook County Circuit Court. The court appointed the Office of the Special State’s Attorney, including Robert Milan, as special prosecutor. After two years of discovery, Milan moved to terminate the judicial review proceedings, arguing the TIRC acted outside its authority. The circuit court granted the motion to terminate and denied Muhammad's motions to rescind Milan's appointment as special prosecutor.Muhammad appealed, and the appellate court reversed the circuit court's orders, finding the TIRC's definition of "tortured confession" was reasonable and that Muhammad's statements qualified as such. The appellate court also found an actual conflict of interest with Milan's appointment and remanded the case for an evidentiary hearing.The Illinois Supreme Court reviewed the case and affirmed the appellate court's decision to reverse the termination of the proceedings under the TIRC Act, agreeing that the TIRC's definition of "tortured confession" was appropriate. However, the Supreme Court reversed the appellate court's decision regarding Milan's appointment, finding no actual conflict of interest. The case was remanded for further proceedings consistent with the Supreme Court's opinion. View "People v. Muhammad" on Justia Law