Justia Illinois Supreme Court Opinion Summaries
Articles Posted in Constitutional Law
People v. Roland
Roland, filed a pro se postconviction petition alleging he received ineffective assistance of counsel during his bench trial for a 2002 attempted murder when his attorney failed to present evidence of his mental health history. After a pre-trial evaluation, Roland had been found fit to stand trial. The expert determined he was legally sane at the time of the offense but that he may have been experiencing symptoms of a depressive mood disorder that was likely exacerbated by alcohol and illegal substances. At trial, Roland testified to having attempted suicide in jail and that he fired a gun while being chased by police because he had wanted police to shoot and kill him.After the petition was advanced to the second stage of proceedings, it was dismissed. The appellate court reversed and remanded for a third-stage evidentiary hearing. The Illinois Supreme Court reinstated the dismissal. It is not reasonably likely that further evidence of Roland’s mental health history would have changed the trial court’s determination that Roland’s conduct during the shooting did not demonstrate that he wanted to commit suicide by police; the court noted that he fled from the police, taking evasive measures to avoid being shot. Roland’s postconviction petition failed to satisfy the prejudice prong of “Strickland.” View "People v. Roland" on Justia Law
People v. Lighthart
Lighthart had dated both Buchanan and the victim, who was known to have access to large amounts of money. Lighthart drove the victim to a residence, knowing that Buchanan was there intending to rob the victim. Buchanan beat the victim, demanding money, and eventually shot him to death. Lighthart then injected the victim with a solution that contained Drano or attempted to do so. After cleaning the scene, they disposed of the body by setting it on fire inside the victim’s Jeep in a rural field. In 2004, Lighthart, then 23, entered a partially negotiated plea of guilty to first-degree murder, in exchange for the dismissal of other charges and a sentencing cap of 35 years. Lighthart filed a motion to reduce her 35-year sentence and, subsequently, an untimely pro se motion to withdraw her plea, asserting that she was the victim of domestic violence and ineffective assistance of counsel. After an 11-½ year delay following remand and changes in counsel, the appellate court affirmed the dismissal of her 725 ILCS 5/122-1 post-conviction petition as untimely.The Illinois Supreme Court reversed. An ineffective notice of appeal from a negotiated guilty plea, which is dismissed for lack of appellate jurisdiction due to failure to follow procedural requirements (Illinois Supreme Court Rule 604(d)) triggers a six-month limitations period for bringing a postconviction petition. However, under the circumstances, Lighthart could not have been culpably negligent in the untimely filing of her petition. View "People v. Lighthart" on Justia Law
Givens v. City of Chicago
In 2012, Givens, Dudley, and Strong burglarized a store and attempted to escape by backing a van out of a closed garage door, striking a police officer. Chicago police officers fired their weapons at the van, resulting in Strong’s death and injuries to Dudley and Givens, who were convicted of felony murder, aggravated battery to a peace officer, and possession of a stolen motor vehicle.Dudley, Givens, and Strong’s estate sued the City, alleging the use of excessive force. With respect to Dudley and Givens, the circuit court granted Chicago summary judgment based on the collateral estoppel effect of their prior criminal proceedings. The estate’s lawsuit resulted in a partial verdict for the estate. The circuit court granted Chicago’s motion for judgment notwithstanding the verdict (JNOV) based on the jury’s answers to special interrogatories. The appellate court reversed, holding that collateral estoppel did not bar Dudley and Givens from litigating their claims and the circuit court erred in vacating the verdict.The Illinois Supreme Court agreed that collateral estoppel did not bar the suit by Dudley and Givens. Chicago did not establish with “clarity and certainty” that the identical question was decided in the earlier proceeding The court reinstated the JNOV. The circuit court properly held that the jury’s special finding related to an ultimate issue of fact upon which the rights of the parties depended and was clearly and absolutely irreconcilable with the verdict returned. View "Givens v. City of Chicago" on Justia Law
People v. Pacheco
Pacheco was convicted of aggravated assault and other offenses after he tried to hit a Joliet police officer with his car. During the incident, the officer shot and injured Pacheco. The appellate court reversed, finding that the trial court violated Pacheco’s right to confrontation by prohibiting defense counsel from cross-examining the officer who shot Pacheco as to whether the officer believed he could lose his job if the shooting was found to be unjustified and finding the trial court erred in granting the prosecution’s motion in limine to bar defense counsel from asking the officer and his partner why they did not write police reports regarding the incident.The Illinois Supreme Court reversed the appellate court and remanded. The limitation imposed on the officer’s cross-examination was necessary to avoid a highly prejudicial outcome to Pacheco–the admission of testimony that a review panel had found the shooting to be justified. Cross-examination was not otherwise limited. Because of department policy, the officers had no choice about writing reports and their failure to do so was irrelevant to any question of bias or credibility. The question would have distracted the jury from the question of determining the guilt or innocence of Pacheco. View "People v. Pacheco" on Justia Law
People v. Lozano
Chicago police arrested Lozano, who was subsequently charged with burglary and possession of burglary tools. Lozano moved to suppress evidence (a car radio, a wallet, and two screwdrivers) arguing that when the officers stopped, detained, and searched him, they neither possessed a warrant nor saw him committing any crimes and could not reasonably suspect that he had committed or was about to commit any crimes or that he was armed and dangerous. Officer Rodriguez testified that he and his partner were driving in an unmarked car, on patrol, and saw Lozano “running at a fast rate of speed” and holding his front pocket. It was raining and wet outside. Rodriguez made a U-turn and approached Lozano, who fled up the stairs of an apparently abandoned building. Rodriguez pursued Lozano and saw a “big bulge” in Lozano’s pocket. Rodriguez handcuffed Lozano, then touched his hooded sweatshirt and felt a rectangular box. He reached inside Lozano’s front pocket and recovered a wallet, two screwdrivers, and a radio. The wallet and radio had been taken from a parked car.The Illinois Supreme Court reversed the trial and appellate courts and held that the officers lacked reasonable suspicion to stop Lozano. The act of running in the rain while holding the front of his pocket did not provide a reasonable suspicion of criminal activity to justify an investigatory stop consistent with the Fourth Amendment and the Illinois Constitution. View "People v. Lozano" on Justia Law
Caulkins v. Pritzker
The Protect Illinois Communities Act restricts firearms and related items that the Act defines as “an assault weapon, assault weapon attachment, .50 caliber rifle, or .50 caliber cartridge” (assault weapons), 720 ILCS 5/24-1.9(b), and “large capacity ammunition feeding device[s],” section 24-1.10(b)). Certain restrictions do not apply to law enforcement agencies and individuals who complete firearms training as part of their employment in law enforcement, corrections, the military, and private security (trained professionals), and individuals who possessed assault weapons or LCMs (large capacity magazines) before the restrictions became effective.The circuit court of Macon County entered declaratory judgment, finding that the restrictions facially violated the Illinois Constitution because the exemptions deny the “law-abiding public” equal protection and constitute special legislation. On appeal, opponents of the law alleged for the first time that, regardless of the exemptions, the restrictions violate the second amendment to the U.S. Constitution and violated the three-reading requirement of the Illinois Constitution.The Illinois Supreme Court reversed. The exemptions neither deny equal protection nor constitute special legislation because plaintiffs have not sufficiently alleged that they are similarly situated to and treated differently from the exempt classes. The plaintiffs expressly waived in the circuit court any independent claim that the restrictions impermissibly infringe the Second Amendment and are jurisdictionally barred from renewing their three-readings claim. View "Caulkins v. Pritzker" on Justia Law
Rowe v. Raoul
The Illinois Supreme Court Commission on Pretrial Practices made multiple recommendations to “ensure defendants are not denied liberty solely due to their inability to financially secure their release from custody.” In 2021, the General Assembly passed, and the Governor signed, the Safety, Accountability, Fairness, and Equity-Today (SAFE-T) Act, revising the standards for police use of force, conferring new authority on the Attorney General concerning alleged civil rights violations by law enforcement, and imposing new requirements for correctional facilities.The Act rebuilt Illinois’s statutory framework for the pretrial release of criminal defendants, 725 ILCS 5/110, establishing a default rule that all persons charged with an offense are eligible for pretrial release on personal recognizance subject to conditions of release, such as electronic monitoring or home supervision. Although the Act eliminates monetary bail it allows the court to order pretrial detention of criminal defendants in specified cases. The prosecution bears the burden of establishing a defendant’s eligibility for pretrial detention.
The trial court rejected claims that the Act violated the state’s constitutional single-subject and three-readings requirements and was void for vagueness but entered summary judgment, finding that certain provisions violated the bail, crime victims’ rights, and the separation of powers clauses of the Illinois Constitution.The Illinois Supreme Court reversed. The Illinois Constitution does not mandate monetary bail as the only means to ensure criminal defendants appear for trials or the only means to protect the public. The Act’s pretrial release provisions set forth procedures commensurate with the balance between the individual rights of defendants and the individual rights of crime victims. The legislature has long regulated the bail system. View "Rowe v. Raoul" on Justia Law
People v. Sneed
The Supreme Court affirmed the judgment of the appellate court reversing the decision of the circuit court finding that the Fifth Amendment privilege against self-incrimination prevented the State from compelling Defendant to provide the passcode for his cell phone, holding that the foregone conclusion doctrine applied as an exception to the Fifth Amendment privilege in this case.Defendant was charged with two counts of forgery stemming from the discovery of two false paychecks made payable to him. The police applied for and obtained a warrant to search Defendant's cell phone but could not execute the warrant because the phone was passcode protected. The State then filed a motion to compel production of the passcode. The circuit court denied the motion, concluding that compelling Defendant to provide the passcode would constitute compelling incriminating testimonial communication and that the foregone conclusion did not apply as an exception to the Fifth Amendment privilege. The appellate court reversed. The Supreme Court affirmed, holding that the foregone conclusion applied in this case. View "People v. Sneed" on Justia Law
People v. Taylor
Illinois State Trooper Scott stopped Taylor on I-80 due to an obstructed windshield. Scott approached Taylor’s vehicle, identified himself, and informed Taylor that he would give him a warning. While Scott was preparing the warning, another officer arrived with a canine unit and walked the canine around Taylor’s vehicle. The canine alerted. Scott and the other officer asked Taylor to exit his car. Taylor refused and sped off, ultimately parking his vehicle on a country road and grabbing weapons that he had in his vehicle, an AR-15, a semiautomatic rifle, and a handgun. Taylor hid in a cornfield. Scott found Taylor’s car and exited his squad car. Taylor fired 23 shots in Scott’s direction with the AR-15 rifle. Scott was unharmed. Law enforcement officers pursued Taylor, who surrendered several hours later.Convicted of attempted first-degree murder of a peace officer, Taylor was sentenced to 30 years’ imprisonment, plus an additional 20 years for using a firearm during the commission of the offense. The Appellate Court and Illinois Supreme Court affirmed. The trial court did not abuse its discretion in denying his request for a second psychiatric evaluation to determine whether he was not guilty by reason of insanity. Taylor was not subject to an improper double enhancement when he received a 20-year sentence under the firearm enhancement of section 8-4(c)(1)(C), in addition to his 30-year sentence under subsection (A). View "People v. Taylor" on Justia Law
Posted in:
Constitutional Law, Criminal Law
People v. Ramirez
Police executed a search warrant at a Chicago home, forcibly entering the residence after nobody answered. Inside, officers saw Ramirez descending from the second floor. Ramirez was detained but allowed to return upstairs, where he retrieved his shoes from one of the bedrooms. Police searched the house and recovered a 20-gauge Benelli shotgun, a Mossberg shotgun, a 9-millimeter handgun, and ammunition. The Benelli shotgun was recovered from under the mattress of the single bed in the room where Ramirez had retrieved his shoes. From the same bedroom, police recovered mail bearing Ramirez’s name and the home's address. Ramirez was taken into custody, provided Miranda warnings, and made a statement that he bought the Benelli shotgun from a coworker for $100.Ramirez was charged with possession of a Benelli shotgun whose serial number had been “changed, altered, removed or obliterated” (720 ILCS 5/24-5(b)). The state did not present any direct evidence that Ramirez knew that the shotgun’s serial number was defaced. Ramirez did not testify or call any witnesses. The Illinois Supreme Court reversed his conviction. Section 24-5(b)’s implied mens rea of knowledge must apply to both elements of the offense, possession and defacement. The court remanded for a new trial. At the time of trial, binding precedent from an appellate court provided that the state did not have to present evidence that a defendant knew a firearm was defaced. View "People v. Ramirez" on Justia Law