Justia Illinois Supreme Court Opinion Summaries

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

Plaintiffs challenged the constitutionality of a $10 Rental Housing Support Program surcharge collected by the recorder of deeds for the recordation of any real estate-related document in a county, 55 ILCS 5/3-5018. Originally $1 was retained by the county in which it was collected. During the litigation, the section was amended to impose a $9 surcharge to fund the Rental Housing Support Program and a separate $1 recordation fee to be paid to the county. The trial court held both versions of the statute to be unconstitutional. The Illinois Supreme Court reversed. The General Assembly has no evidentiary burden and is not required to produce facts to justify the statute. Plaintiffs failed to establish that the section violated the uniformity clause. The court found a rational basis for the fee: By helping provide affordable housing to low-income families throughout the state, the statute provides needed housing security and financial stability to vulnerable residents and a more stable income stream to landlords. It decreases the number of vacant and abandoned buildings and increases the opportunities for building owners to maintain their property. View "Marks v. Vanderventer" on Justia Law

Defendant was indicted in 2013 for criminal sexual assault and criminal sexual abuse, based on acts he allegedly committed in 2012, when he was 17 years old. At the time of the alleged offenses, the Juvenile Court Act only applied to those minors under 17 years of age, with limited exceptions. Effective January 1, 2014, the exclusive jurisdiction provision of the Juvenile Court Act was amended to apply to minors who were under 18 years of age, 705 ILCS 405/5-120, with a saving clause: “[t]he changes …apply to violations or attempted violations committed on or after the effective date of this amendatory Act.” Defendant filed, in 2014, a “Motion to Declare Adult Prosecution Unconstitutional,” alleging that the saving clause violated his equal protection rights under the federal and state constitutions. Defendant argued that he was similarly situated to 17-year-olds who allegedly committed offenses on or after the amendment’s effective date and there was no rational basis to treat him differently. The circuit court granted defendant’s motion, finding no rational basis for the different treatment. The Illinois Supreme Court reversed; it was reasonable for the legislature to distinguish between the two groups since applying the amendment to offenses committed before the effective date would require those cases to be transferred to the juvenile division and to begin anew. View "People v. Richardson" on Justia Law

Gaytan was a passenger in a car that had a rear-mounted, ball-type trailer hitch. Police officers stopped the car, believing that the trailer hitch obstructed the vehicle’s license plate in violation of the Illinois Vehicle Code (625 ILCS 5/3-413(b)). When the driver of rolled down her window, the officers detected an odor of cannabis. A subsequent search of the car revealed a diaper bag containing cannabis, which the driver indicated belonged to Gaytan, who nodded in agreement that it was his. The officers then arrested Gaytan for unlawful possession of cannabis with intent to deliver (720 ILCS 550/5(d). The circuit court of McLean County denied a motion to suppress evidence in which Gaytan argued that the trailer hitch was not prohibited and, therefore, the officers had no reasonable, articulable suspicion that an offense was being committed when they stopped the car. The appellate court reversed Gaytan’s conviction. The Illinois Supreme Court reinstated the convictions. Although precedent indicated that section 3-413(b) prohibits only those materials which are attached to a license plate the statute is ambiguous. Under the circumstances of this case, it was objectively reasonable for the officers to have believed that the trailer hitch violated the statute. View "People v. Gaytan" on Justia Law

Illinois has five state-funded retirement systems for public employees: the General Assembly Retirement System (GRS); the State Employees’ Retirement System of Illinois (SERS); the State Universities Retirement System (SURS); the Teachers’ Retirement System of the State of Illinois (TRS); and the Judges Retirement System of Illinois (JRS). All provide traditional defined benefit plans and are subject to the pension protection clause of the state constitution. Public Act 98-599 (eff. June 1, 2014), amended the Illinois Pension Code (40 ILCS 5/1-101), reducing retirement annuity benefits for individuals who first became members of four of the systems before January 1, 2011. Members of those systems brought separate actions challenging the amendment under the Illinois Constitution’s pension protection clause. The actions were consolidated. The circuit court of Sangamon County found plaintiffs’ challenge meritorious, declared Public Act 98-599 unconstitutional in its entirety, and permanently enjoined its enforcement, rejecting a contention that the Act could be upheld, notwithstanding its violation of the pension protection clause, based on the state’s reserved sovereign powers. On direct appeal, the Illinois Supreme Court affirmed, stating that although the financial challenges facing Illinois government are well known, “Obliging the government to control itself is what we are called upon to do today.” View "In re Pension Reform Litig." on Justia Law

Barner was convicted of aggravated criminal sexual assault (720 ILCS 5/12-14(a)(1)) and sentenced to natural life in prison. His convictions and sentence were affirmed on appeal. The Illinois Supreme Court later vacated and remanded for reconsideration in light of People v. Williams (2010). The appellate court again affirmed. That decision was vacated by a new supervisory order from the Illinois Supreme Court to reconsider in light of People v. Leach (2012). The appellate court again affirmed. The Illinois Supreme Court affirmed, finding that Barner’s Sixth Amendment right to confrontation was not violated when three state witnesses were allowed to testify concerning the DNA laboratory work and conclusions of nontestifying scientists. None of the documents at issue took the form of an affidavit, attestation, certification, sworn statement, or formal declaration; they lacked the “formality and solemnity” necessary for a statement to be testimonial. The court noted that Barner presented no evidence and did not impeach the state’s witnesses in any significant way, so that any error was harmless beyond a reasonable doubt. Properly admitted evidence overwhelmingly supported the conviction. The main focus at trial did not concern the identification of the attacker, but was the victim’s credibility and her account of the assault. View "People v. Barner" on Justia Law

LVNV collection agency bought Trice’s unpaid debt and filed suit. Trice later sought to vacate a judgment against him on the ground that LVNV was not an Illinois registered agency. The circuit court of Cook County declared sections of the Collection Agency Act (225 ILCS 425/4.5, 14, 14b) unconstitutional. The appellate court remanded after holding that “a complaint filed by an unregistered collection agency is … a nullity, and any judgment entered on such a complaint is void/” The circuit court then found the penalty provisions unconstitutional on grounds of due process, equal protection and vagueness, but held that though LVNV was unlicensed when it filed suit, the resulting judgment should have been “voidable rather than void.” The Illinois Supreme Court vacated the circuit court’s findings, rejected the analysis of the appellate court, and remanded. The circuit court’s initial denial of Trice’s petition was correct, LVNV has been granted relief on a nonconstitutional ground. Failure to comply with a statutory requirement or prerequisite does not negate the circuit court’s subject matter jurisdiction or constitute a nonwaivable condition precedent to that jurisdiction, so there was no need for the circuit court to address the Act’s constitutionality. View "LVNV Funding, LLC v. Trice" on Justia Law

Chicago police officers received a call about a person with a gun in a park. Arriving, officers approached defendant, 19 years old. He walked away. The officers demanded that defendant stop, but he ran. Officers pursued defendant, noticing his hand was on his right waist. An officer witnessed defendant reach inside his waistband and pull out a revolver, which he dropped to the ground. Officers recovered the weapon and found that it was loaded. Defendant was convicted of six counts of violating the aggravated unlawful use of a weapon (AUUW) statute (720 ILCS 5/24-1.6) The court held that, due to its findings of statutory unconstitutionality, facially and as applied, all six AUUW convictions would be vacated and a conviction of unlawful use of a weapon under 720 ILCS 5/24-1(a)(4) would be entered, and imposed a Class A misdemeanor sentence. The Illinois Supreme Court affirmed as to sections 24-1.6(a)(1), (a)(3)(A), and 24-1.6(a)(2), (a)(3)(A) “the firearm possessed was uncased, loaded and immediately accessible at the time of the offense,” but reversed as to sections 24-1.6(a)(1), (a)(3)(C), and 24-1.6(a)(2), (a)(3)(C), “the person possessing the firearm has not been issued a currently valid … [FOID Card] … the person possessing the weapon was under 21 years of age, which it found to be constitutional and severable. Section 24-1.6(d)(2) (sentencing) was invalid, as relying upon the unconstitutional (a)(3)(A) subsection. View "People v. Mosley" on Justia Law