Justia Illinois Supreme Court Opinion Summaries

The Forest Preserve District, filed a condemnation action against defendant's golf course and 54 undeveloped acres in December, 1999. The Eminent Domain Act provided that the date of filing the complaint was to be considered the valuation date for determining just compensation. 735 ILCS 5/7-121. At a trial held nearly eight years later, a jury determined that the fair market value on December 21, 1999, was $10.725 million. The appellate court affirmed in part, but vacated as to value and remanded to determine if the property has materially increased in value. The Supreme Court affirmed. Noting that condemnation can be abandoned and that the owner may have to continue paying taxes after the filing, the court concluded that a taking, to avoid an award of substantially less than fair market value, occurs on the date that the government deposits the amount of compensation that has been awarded and acquires title and the right to possession. Defendant did not forfeit its claim by failing to demand a speedy trial. The court noted that the District has not yet taken title and still could abandon condemnation. The trial court properly concluded that the District engaged in good faith negotiations. View "Forest Pres. Dist. v. First Nat'l Bank" on Justia Law

An inmate, committed under the Sexually Dangerous Persons Act (725 ILCS 205/0.01), claimed deprivation of his right to equal protection because he was not provided with the option to retain an independent psychiatrist to defend against the proceedings, an option afforded similarly situated individuals subject to commitment proceedings under the Sexually Violent Persons Commitment Act (725 ILCS 207/1). The trial court rejected the claim and the appellate court affirmed. The Illinois Supreme Court affirmed, reasoning that an individual subject to commitment under the SDPA, is not similarly situated to individuals subject to commitment under the SVPA. The SDPA concerns individuals who have been charged with any type of criminal offense and suffer from a mental disorder predisposing them to commit sex crimes. The SVPA is limited to persons with mental disorders who have been convicted of serious and violent sex offenses, and are facing potential release or discharge from state custody but continue to pose a risk to commit additional sex crimes. View "People v. Masterson" on Justia Law

Defendant, convicted of first degree murder for a 2003 shooting death, was sentenced to 55 years' imprisonment. On appeal, his arguments included denial of Sixth Amendment right to counsel because police barred his attorney from observing witnesses during a lineup. The appellate court affirmed, finding the evidence closely balanced and applying plain-error analysis. The highest court affirmed after holding that the matter was not within the purview of plain-error review and the evidence was not closely balanced. Even if the right to counsel had attached at the time of the line-up, given the overwhelming evidence of guilt in the record, the defendant could not show prejudice. The record was undeveloped on the issue of whether defendant was entitled to counsel at the line-up, because the issue was not raised at trial. View "People v. White" on Justia Law

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.