Justia Illinois Supreme Court Opinion Summaries

Lewis was charged with involuntary sexual servitude of a minor (720 ILCS 5/10-9(c)(2)), traveling to meet a minor (11- 26(a)), and grooming (i11-25(a)). He asserted the defense of entrapment. Convicted, he was sentenced to six years’ imprisonment. The appellate court reversed the conviction, holding that defense counsel’s cumulative errors rendered the proceeding unreliable under Strickland v. Washington.The Illinois Supreme Court affirmed the remand for a new trial. Defense counsel was ineffective in presenting his entrapment defense where he failed to object to the circuit court’s responses to two jury notes regarding the legal definition of “predisposed,” object to the prosecutor’s closing argument mischaracterizing the entrapment defense and the parties’ relevant burdens of proof, and present defendant’s lack of a criminal record to the jury. View "People v. Lewis" on Justia Law

In 2015, Aljohani was indicted on five counts of first-degree murder in connection with the stabbing death of Talal and one count of armed robbery. The circuit court denied a motion to suppress evidence. The court concluded that the officers’ entry into an apartment fell “squarely within the community caretaking function.” In 2018, Aljohani was convicted and sentenced to 23 years in prison. The appellate court affirmed, citing the emergency aid exception to the warrant requirement.The Illinois Supreme Court affirmed, finding that the evidence was sufficient to prove guilt beyond a reasonable doubt. The police officers had reasonable grounds to believe an emergency existed, having responded to a 911 call about a suspected battery in progress and spoken to a witness, who was “adamant” that someone was seriously hurt. The officers saw an apartment door “wide open,” received no response, and found the victim unresponsive on a bed. The totality of the circumstances at the time of entry provided an objective, reasonable basis for believing someone was injured inside the apartment. View "People v. Aljohani" on Justia Law

In 2017, Brown was charged with violating section 2(a)(1) of the Firearm Owners Identification Card Act (430 ILCS 65/2(a)(1)), which requires a person who possesses a firearm in Illinois to have a Firearm Owners Identification (FOID) card issued by the State Police. Brown challenged section 2(a)(1) as unconstitutional as applied under the Second Amendment. The circuit court dismissed the charge, finding that the legislature did not intend for the FOID Act to apply in a person’s home because “such an interpretation would lead to absurd and unworkable results.”The Illinois Supreme Court stated: “The circuit court’s ruling that section 2(a)(1) … is unconstitutional as applied was not necessary to the resolution of this case. Therefore, we remand this cause … direct that the order … be vacated." When the cause was remanded, the matter proceeded before a new judge, who adopted the reasoning of an Illinois Supreme Court dissent and again found the section unconstitutional as applied.The Illinois Supreme Court again vacated and remanded. The circuit court had no authority to set aside the directions on remand and enter a different order. The mandate was “precise and unambiguous.” On remand, “the circuit court shall not entertain any motion from any party, nor take any action other than entering the modified order.” View "People v. Brown" on Justia Law

Sroga was convicted of a Class A misdemeanor under the Illinois Vehicle Code (625 ILCS 5/4-104(a)(4)) for displaying an unauthorized license plate on a vehicle. He later filed a petition under 735 ILCS 5/2-1401, asserting that his conviction violated the Illinois proportionate penalties clause (Ill. Const. 1970, art. I, 11). He argued that section 3-703 of the Vehicle Code created a Class C misdemeanor covering the same conduct for which he was convicted but imposed a lesser penalty. Neither provision contained an express mental state requirement.The appellate court and Illinois Supreme Court affirmed the dismissal of the petition. The court inferred a requisite mental state of knowledge for Sroga’s section 4-104(a)(4) conviction and concluded that the parallel provision in section 3-703 imposes absolute liability. Although the two offenses criminalize the same physical act, they possess different mental state requirements. Because section 4-104(a)(4) has an inferred mental state of knowledge and section 3-703 imposes absolute liability, the imposition of harsher punishment for a conviction under section 4-104(a)(4) than under section 3-703 is constitutionally sound. View "People v. Sroga" on Justia Law

Responding to a burglary at a Chicago bar in 2009, police found the bar owner in the parking lot with multiple injuries. The man died hours later. Salamon was convicted of first-degree murder, armed robbery, and burglary and sentenced to an aggregate prison term of 33 years.The appellate court and Illinois Supreme Court affirmed. While an inculpatory statement Salamon made to police about two years after the burglary was involuntary and should have been suppressed, the admission of that statement was harmless beyond a reasonable doubt. The court stated that a prolonged incommunicado detention disguised as “normal police procedure” cannot be condoned; an unwarranted delay in providing the simple expedient of a telephone call takes on significant importance in evaluating the voluntariness of an inculpatory statement made after an extended period of incommunicado detention. However, the substance of Salaman’s video-recorded confession was cumulative and duplicated other evidence that was properly admitted at trial, so the result of the trial would have been the same if the confession had been excluded. View "People v.Salamon" on Justia Law

Moon was charged with domestic battery for causing bodily harm to a minor. Before jury selection, the court typically administers a voir dire oath to prospective jurors but the record does not establish whether the court administered a voir dire oath before or during jury selection. The circuit court asked each potential juror several questions. All the prospective jurors indicated that they would follow the court's instructions. After jury selection, the court asked the circuit clerk to swear the jury in. There is no verbatim record of the oath but the parties stipulated that the clerk incorrectly asked the already-selected jurors: “[D]o you solemnly swear or affirm you’ll truthfully answer all questions asked concerning your qualifications as jurors?” Before his conviction, Moon did not object to the unsworn status of the jury. Denying a post-trial motion, the circuit court concluded that the error was harmless. The appellate court concluded that Moon had forfeited and was not prejudiced by this “clear error.”The Illinois Supreme Court held that reversal of Moon’s conviction is required, regardless of the strength of the evidence or any showing of prejudice. Swearing the jury with a trial oath was essential to the common-law system of trial by jury; deprivation of this constitutional right amounts to structural error. A jury must be sworn with an oath that substantially incorporates specific elements. Because jeopardy never attached, the state is not precluded from retrying the defendant on remand. View "People v. Moon" on Justia Law

Jones was a juvenile in 2000 when he pled guilty to first-degree murder and was sentenced to 50 years in prison pursuant to a fully negotiated plea agreement. After unsuccessfully petitioning for postconviction relief, Jones sought leave to file a successive postconviction petition alleging his sentence violated the eighth amendment protections in the Supreme Court’s “Miller v. Alabama” decision.The appellate court affirmed the denial of his motion, finding that Jones’ claims did not invoke the protections provided to juveniles in Miller. The Illinois Supreme Court affirmed. Miller’s additional protections for juvenile offenders apply only when a trial court lacks or refuses to use discretion in sentencing a juvenile offender to life, or to a de facto life, sentence. The mandatory sentencing scheme that applied in Illinois at the time he was sentenced was never applied to Jones. By entering a plea agreement, a defendant forecloses any claim of error. A voluntary guilty plea waives all non-jurisdictional errors or irregularities, including constitutional ones. Jones has not claimed that the state engaged in any misrepresentation or committed any misconduct. View "People v. Jones" on Justia Law

Chicago police officer Luzadder and his partner were on patrol at 11:36 p.m. when they received a dispatch stating that an anonymous person reported that two white females were walking with a white male wearing a black hoodie, who “was swinging at the females” and “has a gun” near a particular intersection. A second call reported that the group had moved north. Minutes later, at the second location, Luzadder saw Carter, a white male, wearing the described clothing, holding his waistband. Luzadder did not see two women nor did he see Carter violate any laws. Luzadder believed that Carter was attempting to conceal a firearm. Luzadder, with a hand on his service weapon, ordered Carter to raise his hands, patted down Carter over his clothes, and felt what he thought was the handle of a handgun. He lifted Carter’s shirt and recovered a revolver from Carter’s waistband. Luzadder arrested Carter, who was charged with being an armed habitual criminal, aggravated unlawful use of a weapon, and unlawful use or possession of a weapon by a felon.The circuit court denied his motion to suppress. The appellate court affirmed the denial of Carter’s motion and his nine-year sentence. The Illinois Supreme Court affirmed in part. The officers had the necessary reasonable suspicion for an investigatory stop. The court otherwise vacated. The state failed to prove Carter guilty beyond a reasonable doubt of armed habitual criminal; the other convictions were merged into that conviction. View "People v. Carter" on Justia Law

Schoonover was charged with predatory criminal sexual assault against his niece, M.L. The prosecution alleged Schoonover, who was over the age of 17, committed “act[s] of contact” with the victim, M.L., who was under the age of 13. Before M.L.’s testimony, the trial court indicated its intention to have the courtroom cleared except for M.L.’s family members and the media during M.L.’s testimony, barring Schoonover’s family members (Code of Criminal Procedure, 725 ILCS 5/115-11).The appellate court majority reversed Schoonover’s convictions and remanded for a new trial, finding the trial court committed second-prong plain error for failing to inquire as to whether the spectators removed from the courtroom during the minor’s testimony had a direct interest in the case.The Illinois Supreme Court reversed, finding no clear or obvious error under section 115-11 or the sixth amendment. The plain language of section 115-11 is clear: the trial court need only formulate an opinion as to whether the spectators being excluded have a direct interest in the case. The determination as to whether a direct interest exists is left to the discretion of the court. Section 115-11 is constitutional and the trial court comported with its requirements and limitations. View "People v. Schoonover" on Justia Law

The Illinois State Police (ISP) revoked Brown’s Firearm Owners Identification (FOID) card due to Brown's 2001 California conviction of a misdemeanor crime of domestic violence (MCDV). On his application, Brown had answered “no” to the question of whether he had ever been convicted of domestic battery or a substantially similar offense. A domestic violence conviction precludes possession of firearms under federal law, 18 U.S.C. 922(g)(9).The Illinois Supreme Court reinstated an order granting Brown’s petition and ordering ISP to issue Brown a FOID card. Under section 10(c) of the FOID Card Act, a circuit court may grant relief to a petitioner whose FOID card has been revoked if the petitioner has not been convicted of a forcible felony under the laws of any jurisdiction within 20 years of the application or at least 20 years have passed since the end of any period of imprisonment imposed in relation to that conviction; the circumstances regarding a criminal conviction, the applicant’s criminal history, and his reputation are such that the applicant will not be likely to act in a manner dangerous to public safety; granting relief would not be contrary to the public interest; and granting relief would not be contrary to federal law.Brown satisfied the federal law test for the “civil rights restored” exception because he lost his right to possess firearms under California law and those rights were subsequently automatically restored by virtue of California law 10 years after his conviction. View "Brown v. Illinois State Police" on Justia Law