Justia Illinois Supreme Court Opinion Summaries

The juvenile was adjudicated delinquent based on findings of criminal sexual assault (720 ILCS 5/12–13(a)(1)) and attempted robbery (720 ILCS 5/8–4(a), 18–1). The trial court ordered him committed for an indeterminate term, to automatically terminate in 15 years or at age 21. The appellate and state supreme courts affirmed. The evidence was sufficient to sustain a conviction, despite some inconsistencies in testimony. The court presumed that the trial court did not allow the juvenile to be shackled without a hearing on whether restraint was required, absent any indication in the record that the court was aware that he was in shackles before he was called to testify. Delinquency adjudications are not the equivalent of felony convictions,so it is not unconstitutional that juveniles do not have a right to a jury trial. Imposition of collateral consequences on juveniles adjudicated delinquent for committing felony sex offenses, such as reduced confidentiality, unavailability of expungement, and possibility of involuntary commitment under the Sexually Violent Persons Act,do not negate the rehabilitative purposes of the Act so that a jury trial would be required. View "In re Jonathon C.B., a Minor" on Justia Law

Defendant was indicted on one count of aggravated drinking under the influence ("DUI") when he was involved in a car accident that killed two people and subsequent tests revealed that his blood contained no alcohol or controlled substances, but his urine contained methamphetamine and amphetamine. At issue was whether the appellate court erred in holding that the state failed to prove that defendant was guilty of aggravated DUI where it presented no evidence of a causal link between a trace amount of methamphetamine found in his urine and the car accident and whether the appellate court erred in holding that the state proved that he was guilty of misdemeanor DUI. The court reversed the appellate court's judgment and held that the state satisfied its burden of proof of misdemeanor DUI where, although the evidence did not establish exactly when defendant last used methamphetamine, a rational jury could have found that his last use was sufficiently recent that some remnants of the drug remained in his urine on the night of the accident. The court also held that defendant's driving was a proximate cause of the victims' death and therefore, defendant was guilty of aggravated DUI.

Defendant was convicted of possession of a controlled substance with intent to deliver and sentenced to nine years in prison after he was arrested during a Chicago police narcotics surveillance operation. At issue was whether the trial court's error in delaying its ruling on defendant's motion in limine to exclude his prior convictions from use as impeachment until after he testified was harmless or reversible. The court held that the trial court's error was harmless where, if the error was removed, a retrial would end up with the same result when the state's case was strong and in light of the inconsistent theory of the defense.

Defendants were each issued a citation for driving under the influence where, in each instance, the first appearance date listed on the citation was beyond the period prescribed by Supreme Court Rule 504. At issue was whether the circuit courts abused their discretion in dismissing the charges with prejudice based on findings that the state did not present any evidence that it was impracticable to comply with Rule 504's time limitations where defendants announced "ready for trial" on his respective appearance date and where the state's failure to proceed to trial at that time constituted a failure to prosecute. The court held that even if the circuit courts had discretion to dismiss due to Rule 504 violations at the time they were decided, the circuit courts abused their discretion in failing to require a showing of prejudice to defendants.