Justia Illinois Supreme Court Opinion Summaries

The issue before the Supreme Court in this appeal was whether the “void sentence rule,” should be abandoned. Defendant Steven Castleberry was convicted on two counts of aggravated criminal sexual assault based on separate acts of oral and vaginal contact with the victim. At sentencing, the State argued that defendant was subject to a mandatory 15-year sentencing enhancement on each of the two counts because the crimes had been committed by defendant while he was armed with a firearm. When added to the mandatory minimum term of 6 years’ imprisonment for each offense, this meant, according to the State, that defendant was subject to a mandatory minimum term of 21 years’ imprisonment on each count. The circuit court disagreed with the State regarding the application of the 15-year enhancement, concluding that the legislature had intended the enhancement to be applied only once under the circumstances presented. The circuit court sentenced defendant to a 9-year term of imprisonment on each count, adding the 15-year enhancement to only one of the counts. The two sentences were ordered to run consecutively, for a total term of 33 years’ imprisonment. On appeal, defendant did not challenge the appellate court’s affirmance of his convictions. Instead, defendant argued that the appellate court erred when it held that the sentence imposed without the statutory enhancement was void. Defendant contended that the rule relied upon by the appellate court (that a sentence which does not conform to statutory requirements was void) was no longer valid in light of recent Illinois Supreme Court decisions and, thus, could not provide a basis for the appellate court to reverse the circuit court’s sentencing order. After review, the Court concluded that its recent decisions indeed undermined the rationale behind the rule to the point that the rule could no longer be considered valid. The Court therefore abolished the rule. View "Illinois v. Castleberry" on Justia Law

In this case, defendant Jorge Guzman argued that the Illinois Supreme Court’s decision in “Illinois v. Delvillar,” (235 Ill. 2d 507 (2009)), should have been overturned based on the United States Supreme Court’s later decision in “Padilla v. Kentucky,” (559 U.S. 356 (2010)). In “Delvillar,” the Illinois Court examined the impact of the failure to give a statutory admonishment on the potential immigration consequences of entering a guilty plea. The Court concluded that the failure to admonish did not affect the voluntariness of the plea, and defendants wishing to withdraw their pleas on that basis were required to demonstrate prejudice or a denial of justice. After review of defendant Guzman’s arguments that the trial court erred in denying him the ability to withdraw his guilty plea, the Supreme Court affirmed the denial. View "Illinois v. Guzman" on Justia Law

M.A., then 13 years old, fought with her 14-year-old brother and cut him with a kitchen knife. M.A. was adjudicated delinquent of several offenses and ordered to register under the Murderer and Violent Offender Against Youth Registration Act, 730 ILCS 154/1. M.A. argued that the registration provisions violated her rights to substantive and procedural due process and equal protection. The Appellate Court rejected the substantive due process claim, but found the registration provisions unconstitutional for violating procedural due process and equal protection. The Illinois Supreme Court reinstated the registration requirement. Current dangerousness is not relevant to the duty to register, so M.A. did not have a due process right to a hearing to address that issue. The Act requires registration solely based upon the fact of conviction or adjudication, which M.A. had a procedurally safeguarded opportunity to contest during her juvenile adjudication proceedings. M.A. did not challenge her adjudication as a juvenile delinquent on appeal. Given that the charges for which M.A. is required to register would be felonies if M.A. committed those acts as an adult, and that those charges require a finding that the offender caused “great bodily harm, permanent disability, or disfigurement,” there is a rational relationship between M.A.’s registration and protection of the public. View "In re M.A." on Justia Law

Stapinski, indicted for unlawful possession of a controlled substance (ketamine) with intent to deliver, 720 ILCS 570/401(a)(10.5), moved to dismiss, arguing that the indictment violated his due process rights and an executed cooperation agreement he had entered into with police. The state did not dispute the existence of the cooperation agreement, but argued that Stapinski did not fulfill his obligations. The Will County trial court dismissed the indictment. The appellate court reversed s. The Illinois Supreme Court reinstated the dismissal. Police entered into a cooperation agreement with Stapinski, promising not to charge him with possession of ketamine if he assisted in the apprehension of others; he fulfilled his obligations under the agreement. His due process rights were violated when, over a year after he was detained by police, he was charged with possession of ketamine. Whether the cooperation agreement was “valid” in the sense that it was approved by the State’s Attorney, is not important. An unauthorized promise may be enforced on due process grounds if a defendant’s reliance on the promise has constitutional consequences. Stapinski relied upon the agreement he made with police and incriminated himself in the process of fulfilling his obligations under the agreement. View "People v. Stapinski" on Justia Law

McElwain, was involved in a traffic accident.. The driver and passenger of the motorcycle that hit McElwain's vehicle had substantial injuries; the passenger died. On the date of the accident, plaintiff was neither issued any tickets nor asked to take any chemical tests. During their investigation, police discovered rolling papers and a bag containing a residue that appeared to be cannabis in McElwain’s vehicle, but officers at the scene did not think he appeared to be under the influence of cannabis. Two days later, McElwain was questioned and admitted that he had smoked marijuana two weeks before the accident. The police issued a ticket for failing to yield when turning left and requested that he take a chemical test. The police read him statutory warnings (625 ILCS 5/11-501.6(c). McElwain refused. The Secretary of State suspended his driver’s license for three years. An ALJ upheld the suspension, rejecting an argument that the officers violated due process by waiting too long. The circuit court and Illinois Supreme Court disagreed, finding the statute unconstitutional as applied. While the state can condition receipt of a driver’s license on a driver’s agreement to consent to a chemical test if he is involved in a serious motor vehicle accident, the essential nexus between the state’s interest in protecting the public from intoxicated drivers and requiring consent to a chemical test following an arrest related to a serious accident no longer exists when the test is requested two days after the accident. View "McElwain v. Ill. Sec'y of State" on Justia Law

Section 15-1504.1 of the Code of Civil Procedure imposes a $50 filing fee in residential mortgage foreclosure cases, two percent of which is retained by the clerk of the court in which the foreclosure complaint is filed,735 ILCS 5/15-1504.1 . The circuit court of Will County found section 15-1504.1 violated the judicial fee officer prohibition in article VI, section 14, of the Illinois Constitution. The Illinois Supreme Court reversed, concluding that fee officer prohibition, were aimed at officers who had a direct role in the adjudicative process of the court system, and were compensated for their services through the payment of fees taxed to the litigants. Although clerks of the circuit courts are officers of the judicial branch of government, they are nonjudicial officers. View "Walker v. McGuire" on Justia Law

The Freeport Journal published an online article concerning Hadley’s decision to again seek election to the Stephenson County Board. Online readers could post comments after completing a basic registration. “Fuboy” posted: “Hadley is a Sandusky waiting to be exposed. Check out the view he has [an elementary school] from his front door” and “Anybody know the tale of Hadley’s suicide attempt? ….” Hadley filed a defamation lawsuit against the Journal and its parent company. The company provided Hadley the IP address acquired from Fuboy’s internet service provider, Comcast. The federal court dismissed the suit against as barred by federal statute. Hadley returned to state court with a defamation action against Subscriber Doe a/k/a “Fuboy” and issued a subpoena to Comcast. The circuit court directed Comcast to comply and to notify the subscriber. An attorney moved to quash. The court stated that the better procedure to discover Fuboy’s identity would be Illinois Supreme Court Rule 224, under which Hadley would have the burden of setting forth allegations that would be sufficient to withstand a motion to dismiss under Code of Civil Procedure 2-615, even if such a motion was not filed. The court allowed Hadley to add a count, directed at Comcast, seeking relief under Rule 224. The court concluded that count I could withstand a motion to dismiss, so Hadley was entitled to Rule 224 relief. The court found that the comment imputed the commission of a crime to Hadley; was not capable of innocent construction; and could not be considered an opinion. The court directed Comcast to provide identification. The appellate court and Illinois Supreme Court affirmed. Hadley’s complaint states facts to establish a defamation cause of action sufficient to withstand a section 2-615 motion, so the court properly concluded that necessity was established under Rule 224. View "Hadley v. Subscriber Doe" on Justia Law

Defendant was charged with first degree murder. After the presentation of the evidence, the circuit court instructed the jurors. The term “reasonable doubt” appeared in three instructions: “The defendant is presumed to be innocent of the charges against him. This presumption remains with him throughout every stage of the trial and during your deliberations on the verdict. It is not overcome unless from all the evidence in this case you are convinced beyond a reasonable doubt that he is guilty.” “The State has the burden of proving the guilt of the defendant beyond a reasonable doubt, and this burden remains on the State throughout the case. The defendant is not required to prove his innocence.” The third instruction sets forth specific propositions that the state must prove to sustain the charge of first degree murder: “If you find from your consideration of all the evidence that each one of these propositions has been proved beyond a reasonable doubt, you should find the defendant guilty. If you find from your consideration of all the evidence that any one of these propositions has not been proved beyond a reasonable doubt, you should find the defendant not guilty.” During deliberations, the jury sent a note asking for a definition of “reasonable doubt.” The court’s written reply stated: “We cannot give you a definition it is your duty to define.” The jury found defendant guilty. Following post-trial proceedings, the court sentenced defendant to 70 years’ imprisonment. The appellate court vacated defendant’s conviction and remanded for a new trial. The Illinois Supreme Court reversed and reinstated defendant’s conviction. Defendant failed to show that a clear or obvious error occurred, so his procedural default of the reasonable doubt claim must be honored. View "People v. Downs" on Justia Law

The state filed a petition for adjudication of wardship, alleging that D. had committed first degree murder. D. was nine years old; the victim was 14 months old. The circuit court found D. unfit to stand trial and subsequently found him “not not guilty” of murder. Thecourt remanded D. to the Department of Human Services for fitness restoration education, so that D. may become fit and be tried for murder. The appellate court reversed, finding that the trial court erred in denying a suppression motion. The Illinois Supreme Court remanded for “harmless error analysis,” noting that in interviewing D., a detective seized on D’s fear that his father or others in the household would go to jail, or that he, himself, would be taken away. The detective promised D that no matter what he said, no one was going to jail, no one would be in trouble, he would not be taken from his father and, at the end of the day, he could go to his grandmother’s house and “hang out” with his dad. The detective reinforced that no consequences would follow an admission that D hit the victim and rejected repeated denials, making plain that anything less than an admission was unacceptable. The detective stated that whatever happened was a mistake, and everybody makes mistakes, and was explicit about the admission that would suffice—an admission that D. hit the baby once .D eventually admitted to hitting the infant once. D., functioning at the level of a seven- or eight-year-old, was especially vulnerable and susceptible to police coercion. View "In re D.L.H." on Justia Law

Police received a hotline tip that LeFlore was committing burglaries in Aurora; learned that he was on mandatory supervised release from prison and that he had been recently arrested for fleeing in a car registered to his address; and placed a Global Positioning System (GPS) device on the car. The GPS showed the car parked near a gas station when it was held up. The robbery was caught on a surveillance camera. LeFlore was charged. He confessed before learning of the use of the GPS and was identified by the cashier. He unsuccessfully moved to quash arrest and suppress evidence. LeFlore was convicted. While appeal was pending, the U.S. Supreme Court held in United States v. Jones, that attachment of a GPS device and its use to monitor vehicle movements on public streets was a search under the fourth amendment The appellate court reversed. The Illinois Supreme Court remanded for a new trial for failure to properly admonish defendant (Supreme Court Rule 401(a)), but, with respect to use of the GPS, held that the good-faith exception applies and that the evidence should not be excluded. There was “binding appellate precedent” that police could have reasonably relied upon in using the GPS in 2009 and it would have been objectively reasonable for police to rely upon the legal landscape and constitutional norm that had been established at that time, allowing warrantless attachment and use of GPS technology. The court found no police culpability and that there would be little deterrent value to suppressing the evidence. View "People v. LeFlore" on Justia Law