Justia Illinois Supreme Court Opinion Summaries

The plaintiffs in this case were former hourly employees of Amazon who worked in the company’s Illinois distribution warehouses. In March 2020, in response to the COVID-19 pandemic, Amazon required all hourly, nonexempt employees to undergo mandatory medical screenings before clocking in for their shifts. These screenings included temperature checks and health questions, and typically took 10 to 15 minutes, sometimes causing employees to clock in after their scheduled start time. Plaintiffs alleged that Amazon violated wage laws by not compensating employees for the time spent in these screenings, arguing the screenings were necessary to their work and primarily benefited Amazon by enabling continued operations during the pandemic.The plaintiffs initially filed a class-action complaint in the Circuit Court of Cook County, asserting claims under both the federal Fair Labor Standards Act (FLSA) and the Illinois Minimum Wage Law. Amazon removed the case to the United States District Court for the Northern District of Illinois, which dismissed the complaint. The district court held that the FLSA claims were barred by the Portal-to-Portal Act (PPA), which excludes certain preshift activities from compensable time, and summarily concluded the state law claims failed for the same reason. Plaintiffs appealed to the United States Court of Appeals for the Seventh Circuit, which certified to the Supreme Court of Illinois the question of whether Illinois’s Minimum Wage Law incorporates the PPA’s exclusion for preliminary and postliminary activities.The Supreme Court of Illinois held that section 4a of the Illinois Minimum Wage Law does not incorporate the PPA’s exclusion for preliminary and postliminary activities. The court reasoned that the plain language of the statute and relevant state regulations do not contain such an exclusion and that the Illinois Department of Labor explicitly defines compensable hours to include all time an employee is required to be on the premises. The court thus answered the certified question in the negative. View "Johnson v. Amazon.com Services, LLC" on Justia Law

Two individuals, Taurean Tyler and DeAngelo Mixon, were shot from behind while walking to a friend’s house in Chicago; Tyler died, and Mixon survived. The identity of the shooter was the sole contested issue at trial. Four eyewitnesses testified: Mixon and Tristan Thomas, both friends of the victims who knew the defendant, Antrell Johnson, for years, initially identified Johnson as the shooter in out-of-court statements but tried to recant at trial. Janeese Washington, an uninvolved bystander, consistently identified Johnson, both in a photo array and at trial, while her husband, Robert Laster, did not make an identification. There was no physical evidence or motive linking Johnson to the crime.A jury in the Circuit Court of Cook County found Johnson guilty of first degree murder but acquitted him of attempted murder. Johnson’s posttrial motion challenging the sufficiency of the evidence was denied. On appeal, a divided panel of the Appellate Court of Illinois, First District, reversed the conviction, finding the State failed to prove guilt beyond a reasonable doubt. The majority applied the reliability factors from Neil v. Biggers, typically used for assessing suggestive identification procedure admissibility, instead of the sufficiency of the evidence standard from Jackson v. Virginia. The appellate majority also relied on social science research not presented at trial and cited the split verdict as undermining the reliability of the identifications.The Supreme Court of the State of Illinois reversed the appellate court’s judgment. It held that the appellate court erred by substituting the Biggers admissibility test for the Jackson sufficiency standard, by improperly considering extra-record social science literature, and by relying on the split verdict to undermine the jury’s credibility determinations. The Illinois Supreme Court found the identification evidence sufficient for conviction and remanded the case for appellate consideration of the ineffective assistance of counsel claim. View "People v. Johnson" on Justia Law

In 1986, a liquor store robbery in Chicago resulted in the shooting death of the store’s owner, Nazih Youssef. Multiple eyewitnesses identified Michael McCoy and another man, Wayne Millighan, as present during events leading up to the crime; two witnesses specifically identified McCoy as the shooter both at the scene and in court. Physical evidence included a presumptive blood test on McCoy’s shoes, though this could not conclusively identify the substance as human blood. McCoy was arrested shortly after the crime, matching the descriptions given by witnesses.After a jury trial in the Circuit Court of Cook County, McCoy was convicted of first degree murder and armed robbery and sentenced to life imprisonment. His convictions were affirmed on direct appeal by the Illinois Appellate Court. Over the years, McCoy filed several postconviction petitions, all of which were denied. Eventually, he was granted leave to file a successive postconviction petition, raising claims of actual innocence based on new affidavits from Millighan naming another man as the shooter, expert testimony questioning the reliability of eyewitness identifications, and expert analysis challenging the blood evidence.The Circuit Court held a third-stage evidentiary hearing but denied relief, finding that Millighan’s new testimony was not credible and that the expert evidence was not conclusive enough to probably change the result at retrial. The Illinois Appellate Court affirmed, concluding that the outcome hinged on Millighan’s credibility, which the Circuit Court was best positioned to assess.The Supreme Court of the State of Illinois reviewed the case and affirmed the lower courts’ decisions. The court held that McCoy failed to establish by a preponderance of the evidence that the new evidence was of such a conclusive character that it would probably change the result upon retrial; thus, denial of his successive postconviction petition was not manifestly erroneous. View "People v. McCoy" on Justia Law

The defendant was incarcerated in Will County, Illinois, awaiting trial on charges of sexual abuse. While in jail, he approached two different inmates on separate occasions, offering them money to murder individuals connected to the sexual abuse case, including the alleged victims and two detectives. The second inmate, Daniel Robinson, reported the solicitation to authorities and cooperated with law enforcement by recording conversations with the defendant in which they discussed plans and payments. The defendant transferred money and property to Robinson as part of these arrangements. Robinson never intended to commit the murders and was acting in coordination with investigators.A Will County jury convicted the defendant of two counts of solicitation of murder for hire and five counts of solicitation of first degree murder. The five solicitation of murder convictions were merged with the two solicitation of murder for hire convictions. The Circuit Court of Will County sentenced him to consecutive prison terms of 39 and 37 years. The defendant appealed, arguing that his convictions for solicitation of murder for hire could not stand because the person he solicited did not actually intend to carry out the murders, and therefore the statutory requirement that he “procure another” was not met. The Illinois Appellate Court, Third District, affirmed the convictions, finding that a conviction could be supported even if the person solicited only feigned agreement.The Supreme Court of the State of Illinois granted leave to appeal to determine whether the offense of solicitation of murder for hire requires proof that the person solicited genuinely intended to commit murder. The court held that, under Illinois law, solicitation of murder for hire encompasses unilateral agreements; the defendant’s intent and actions to procure another, regardless of the other party’s true intent, are sufficient for conviction. The court affirmed the judgments of the lower courts. View "People v. Shepherd" on Justia Law

The case concerned a man charged with multiple offenses, including aggravated domestic battery, based on an incident involving his former partner. The relationship between the two was characterized by recurring conflicts and accusations, leading to several prior incidents of alleged domestic violence. At trial, the prosecution presented evidence of four prior incidents of defendant's alleged violence, one of which resulted in defendant's acquittal in an earlier criminal proceeding. The defendant claimed self-defense and sought to introduce evidence of the complainant’s violent conduct occurring after the charged offenses, as well as evidence of his earlier acquittal.The Circuit Court of Kankakee County allowed the prosecution to introduce evidence of the four earlier incidents but barred the defendant from presenting evidence of the complainant’s subsequent violent conduct, reasoning that such conduct postdated the charged offenses. The court also excluded evidence of the defendant's prior acquittal, concluding that a not-guilty verdict did not equate to innocence. The jury convicted the defendant on several charges, and he was sentenced to prison. On appeal, the Illinois Appellate Court vacated the convictions, holding that evidence of the complainant's subsequent conduct was admissible and that it was an abuse of discretion to exclude the acquittal evidence.The Supreme Court of Illinois held that under Illinois Rule of Evidence 405(b)(2), only evidence of the alleged victim’s violent conduct that occurred prior to the charged offense is admissible in battery or homicide cases where self-defense is raised. The court also held that while it was an abuse of discretion to bar evidence of the prior acquittal, the error was harmless given the overall evidence. The appellate court’s judgment was reversed, and the case remanded for consideration of remaining claims. View "People v. Heintz" on Justia Law

In this case, the defendant was sentenced in 1995 to mandatory natural life imprisonment after being convicted of a third Class X felony, as required by the habitual criminal statute then in effect. His first Class X felony was committed at age 17. In 2021, the Illinois legislature amended the relevant statute to require that a person’s first Class X felony must have been committed at age 21 or older for a mandatory natural life sentence to apply. The defendant sought postconviction relief, arguing that the amended statute should apply to him because his first offense was committed when he was under 21.After his conviction and direct appeal—which was affirmed by the Illinois Appellate Court—the defendant filed several unsuccessful collateral attacks on his conviction and sentence. Following the 2021 statutory amendment, he filed motions for leave to file successive postconviction petitions in the Circuit Court of Cook County, seeking resentencing under the new law. The circuit court denied the motions, holding that the amendment applied only prospectively and did not impact his sentence.On appeal, the Illinois Appellate Court reversed, concluding that the 2021 amendment should be interpreted as a clarification of the original statute and thus applied retroactively, rendering the defendant’s mandatory life sentence invalid since his first offense was committed before age 21.The Supreme Court of the State of Illinois reviewed the case and disagreed with the appellate court. The court held that the 2021 amendment to section 5-4.5-95(a) of the Unified Code of Corrections neither applies retroactively nor constitutes a clarification of the law as it existed in 1995. The court concluded that the circuit court properly denied the defendant’s motions for leave to file successive postconviction petitions. The Supreme Court of Illinois reversed the appellate court’s judgment and affirmed the circuit court’s decision. View "People v. Brown" on Justia Law

Residents near a medical-equipment sterilization facility in Willowbrook, Illinois, brought a mass tort action alleging that Griffith Foods International, Inc., and its successor Sterigenics U.S., LLC had emitted ethylene oxide (EtO) for more than 35 years, resulting in cancer and other illnesses. The policyholders held commercial general liability (CGL) insurance policies issued by National Union Fire Insurance Company of Pittsburgh, PA, covering 1983-1985, which included a standard pollution exclusion clause. The policyholders sought a declaration in federal court that the insurer had a duty to defend them in the underlying tort litigation.The United States District Court for the Northern District of Illinois ruled in favor of the policyholders, holding that the pollution exclusion did not bar coverage because the EtO emissions were authorized under a permit from the Illinois Environmental Protection Agency (IEPA). National Union appealed to the United States Court of Appeals for the Seventh Circuit. The Seventh Circuit, noting conflicting interpretations of Illinois law regarding the relevance of permits to pollution exclusions, certified a question to the Supreme Court of Illinois for clarification.The Supreme Court of Illinois reviewed the certified question. The court held that a permit or regulation authorizing emissions has no relevance in determining the application of a pollution exclusion in a standard-form CGL policy. The holding clarifies that coverage is barred for injuries arising out of the discharge of pollutants regardless of whether the emissions were authorized by a governmental permit. The court explicitly overruled contrary appellate decisions in Erie Insurance Exchange v. Imperial Marble Corp. and Country Mutual Insurance Co. v. Bible Pork, Inc., and stated that the existence of a permit does not create ambiguity or exception to the pollution exclusion. The certified question was answered accordingly. View "Griffith Foods International Inc. v. National Union Fire Insurance Company of Pittsburgh, PA" on Justia Law

The plaintiff, who is a type 1 diabetic, received treatment from the defendants for foot pain following an injury. Over several visits in January 2017, the treating physician diagnosed cellulitis and prescribed antibiotics and pain medication, but did not diagnose a fracture. Subsequent evaluation by a podiatrist revealed a dislocated fracture and other breaks in the foot, which ultimately led to multiple surgeries and the amputation of the plaintiff’s left leg below the knee. The plaintiff alleged that the physician misdiagnosed his condition, causing him to continue using the injured foot and suffer further harm.A jury trial was held in the Circuit Court of Adams County, and after six days of testimony, the jury deliberated and returned a verdict for the defendants. During deliberations, the jury sent several notes to the court, including one from a juror who expressed personal belief in the physician’s negligence but agreed to sign the verdict for the defendants to end deliberations. The plaintiff’s counsel moved for a mistrial based on this note, but the trial court denied the motion, gave the jury a supplemental Prim instruction to guide further deliberations, and subsequently polled the jury after the verdict was reached. All jurors affirmed the verdict. The trial court also denied motions for a new trial and for additional polling of jurors.The Appellate Court, Fourth District, affirmed the trial court’s rulings, finding no abuse of discretion. Upon further appeal, the Supreme Court of the State of Illinois held that the trial court did not abuse its discretion in denying the motion for a mistrial or refusing to conduct additional polling. The Supreme Court affirmed the appellate court’s judgment, upholding the verdict for the defendants. View "Schilling v. Quincy Physicians & Surgeons Clinic, S.C." on Justia Law

Gregory Dobbins was wrongfully convicted of possession of a controlled substance in Cook County, Illinois, based on fabricated evidence supplied by a corrupt police sergeant and his team. After serving prison time, Dobbins filed for post-conviction relief, and in April 2022, the circuit court vacated his conviction and the State dismissed the charges against him. Shortly after, Dobbins submitted a petition for a certificate of innocence (COI), which would allow him to seek compensation for his wrongful conviction. However, Dobbins passed away before the scheduled hearing on his COI petition.Following his death, his life partner and estate administrator, Katrina Crawford, moved to substitute herself as petitioner to continue the COI action on behalf of Dobbins’s estate. The circuit court denied this motion and dismissed the COI petition, ruling that the right to a COI is a personal statutory right that does not survive the petitioner’s death. The Appellate Court of Illinois, First District, affirmed the circuit court’s decision, reasoning that the COI statute did not permit estates to seek a COI and that a COI action is not a claim for damages that survives under the Survival Act.The Supreme Court of the State of Illinois reviewed the case and affirmed the lower courts’ judgments. The court held that a petition for a COI is not an action to recover damages but rather a condition precedent to seeking compensation in the Court of Claims. Because the COI itself does not confer damages, the cause of action does not survive the petitioner’s death under the Survival Act. Therefore, the Supreme Court affirmed the dismissal of the petition and denied substitution by the estate. View "People v. Dobbins" on Justia Law

A company sought approval from the Illinois Commerce Commission (ICC) to construct and operate a high-voltage transmission line for renewable energy, running from Kansas through parts of Illinois to Indiana. The applicant, a special purpose entity owned by Invenergy, did not have existing utility assets in Illinois and planned to use a common energy industry “project finance” model—securing long-term contracts and commercial agreements after regulatory approval to finance construction through a combination of debt and equity. The applicant presented testimony regarding its management’s extensive experience with large-scale energy projects and relationships with major lenders, but did not submit traditional financial statements.The ICC reviewed the application, accepted evidence about the applicant’s financing strategy and experience, and imposed a condition that required the applicant to secure full financing for the entire project before beginning any construction on Illinois easement property. The ICC found that the applicant satisfied the statutory requirement to be “capable of financing the proposed construction without significant adverse financial consequences” for the utility or its customers, and issued the certificate of public convenience and necessity (CPCN).On direct administrative review, the Appellate Court of Illinois, Fifth District, reversed the ICC’s grant of the CPCN. The appellate court concluded that the applicant failed to show it could currently finance the project at the time of the certificate’s issuance, and characterized the project finance method as speculative. It held that section 8-406.1(f)(3) of the Public Utilities Act required proof of present financing capability as a condition precedent to granting a CPCN.The Supreme Court of Illinois reversed the appellate court’s judgment and affirmed the ICC’s decision. The court held that section 8-406.1(f)(3) does not require an applicant to prove current, present financing capability at the time of certificate issuance. Instead, it requires a showing of capacity to finance without significant adverse financial consequences, which may be established by substantial evidence of future financing ability and industry practices. The case was remanded to the appellate court for further proceedings on unaddressed issues. View "Concerned Citizens & Property Owners v. Illinois Commerce Comm'n" on Justia Law