Justia Illinois Supreme Court Opinion Summaries

Based on a 2001 gang-related shooting Jackson was convicted in Cook County of first-degree murder and aggravated battery with a firearm. After his direct appeal and an initial post-conviction petition were unsuccessful, he sought leave in the circuit court to file a successive post-conviction petition, arguing that his constitutional right to due process of law was violated at trial by the state’s use of witness statements that were the product of police intimidation or coercion and that he is actually innocent of the crimes for which he was convicted. Jackson attached documents that purport to show a pattern and practice of witness intimidation in other cases by the police detectives who obtained the witness statements, as well as exculpatory affidavits.The appellate court and Illinois Supreme Court affirmed the denial of the petition. The material regarding police misconduct attached to Jackson’s petition is not relevant to establishing a pattern and practice of witness intimidation by the interviewing detectives in this case, so Jackson has not satisfied the “prejudice” prong of the cause-and-prejudice test. Jackson cannot set forth a colorable claim of actual innocence because his supporting affidavits are not new; principles of “fundamental fairness” do not require additional proceedings. View "People v. Jackson" on Justia Law

Knapp and Rodriguez were charged with attempted first-degree murder, mob action, and aggravated battery in connection with the stabbing of Avitia, who survived the attack and identified the assailants. At a McHenry County jury trial, the prosecution argued that the defendants were members of the Norteños street gang and that they attacked Avitia based on his alleged association with a rival street gang. At the state’s request, the court admonished Knapp concerning his right to testify. Knapp acknowledged that he had discussed the issue with his attorney and made a choice not to testify.On appeal, Knapp unsuccessfully argued that his counsel was ineffective because counsel “elicited inadmissible other crimes evidence that was similar to the charged offense and also false” and failed to “pursue a ruling on the State’s motion to introduce gang evidence or renew his objection to the admission of such evidence.” Knapp then filed a pro se post-conviction petition, raising claims of actual innocence, involuntary waiver of his right to testify, and ineffective assistance.The appellate court and Illinois Supreme Court affirmed the summary dismissal of the petition. While a pro se petitioner is not required to use precise legal language alleging a “contemporaneous assertion of the right to testify” to survive first-stage summary dismissal, summary dismissal is warranted when the record positively rebuts the allegations. The record contains nothing to suggest that Knapp ever alerted the court of his desire to testify, that he had any questions about that right, or that he otherwise was unsure about waiving his right to testify. View "People v. Knapp" on Justia Law

Reents obtained a tax deed to 10 locked and gated acres in Rockford. In 2017, the Attorney General, at the request of the Illinois Environmental Protection Agency, filed a civil enforcement action for violations of 415 ILCS 5/1, against Reents and Stateline Recycling, including allegations of open dumping of waste without a permit; disposal, storage, and abandonment of waste at an unpermitted facility; open dumping of waste resulting in litter and the deposition of construction and demolition debris; and failure to pay clean construction and demolition debris fill operation fees. Reents refused to permit an inspection of the property during pretrial discovery. The Winnebago County circuit court granted a motion to compel her to comply with the Rule 214(a) inspection request. After Reents asserted a good-faith objection and respectfully refused to comply, the court held her in contempt so that she could file an appeal. The appellate court reversed, citing Fourth Amendment principles.The Illinois Supreme Court vacated. The appellate court erred in deciding the appeal on constitutional grounds; the issue presented involves a civil discovery order that the appellate court should have reviewed for an abuse of discretion. Reents did not raise any constitutional issues and has forfeited any such challenge. Courts should not find discovery rules unconstitutional when a particular case does not require it. The circuit court applied the plain language of Rule 214(a) as written. View "Madigan v. Stateline Recycling, LLC" on Justia Law

In 2002, Lusby was convicted of first-degree murder, aggravated criminal sexual assault, and home invasion and sentenced to 130 years’ imprisonment. Though he was 23 years old at the time of the trial, he was only 16 years old at the time of the offenses. After an unsuccessful direct appeal and post-conviction proceedings, he sought leave to file a successive post-conviction petition, asserting that his sentencing hearing was constitutionally inadequate under the Supreme Court’s 2012 decision, Miller v. Alabama. The Will County Circuit Court denied that motion. The appellate court reversed.The Illinois Supreme Court reinstated the trial court’s decision, denying relief. Lusby failed to show cause and prejudice such that the trial court should have granted leave to file a successive post-conviction petition. Lusby had every opportunity to present mitigating evidence but chose not to offer any. The trial court considered his youth and its attendant characteristics before concluding that his future should be spent in prison. The de facto discretionary life sentence passes constitutional muster under Miller; Lusby has not shown prejudice under 725 ILCS 5/122-1(a)(1). Miller does not require a court to use “magic words” before sentencing a juvenile defendant to life imprisonment but only requires consideration of “youth-related factors.” View "People v. Lusby" on Justia Law

After a dispute at his parents’ house, Gaines was charged with criminal damage to property, criminal trespass to a residence, misdemeanor criminal damage to property, misdemeanor domestic battery, and misdemeanor aggravated assault. At a hearing, the judge initially accepted a negotiated plea to two counts, but subsequently rejected the plea and reinstated the charges. At trial, Gaines was convicted of felony criminal trespass to a residence and misdemeanor domestic battery. Gaines did not raise a double jeopardy argument in post-trial motions. The appellate court ordered his release.The Illinois Supreme Court reversed, reinstating the misdemeanor battery conviction. In the context of a guilty plea proceeding, jeopardy attaches when the court unconditionally accepts the guilty plea. A formal finding of guilt is not required, nor is imposition of a sentence. The court unconditionally accepted Gaines’s guilty plea; jeopardy attached. Jeopardy did not, however, terminate improperly, where the court sua sponte vacated the guilty plea. The court did not abuse its discretion because it had “good reason to doubt the truth of the plea.” Because jeopardy did not terminate improperly, (720 ILCS 5/3-4(a)), Gaines’s subsequent trial on the same offense did not violate the prohibition against double jeopardy. Gaines cannot demonstrate prejudice, so his claim of ineffective assistance of counsel fails. View "People v. Gaines" on Justia Law

Hollahan was charged with aggravated DUI. His initial jury trial ended in a mistrial when a video recording of the traffic stop was inadvertently played beyond the point of admissible evidence. During a second jury trial, a redacted video of the traffic stop was played for the jury. Following the presentation of evidence, closing arguments, and instruction as to the applicable law, the jury retired to deliberate. Shortly thereafter, the jury asked to watch the video again. The judge granted that request. The video was shown to the jury in the courtroom because the court did not have the “arrangement” necessary to allow the jury to view the video in the jury deliberation room. The court allowed Hollahan, the attorneys, and two alternate jurors to remain in the courtroom while the jury watched the video. Defense counsel did not object. Before the jury was returned to the courtroom, the court admonished that the jury would be watching the video and that “[n]o one will have any conversation.” The judge told the jurors, “we will not be talking to you other than to get the video, period.” After watching the video, the jury returned to the jury room and found Hollahan guilty.The Illinois Supreme Court found no reversible error. Deliberations were not taking place while the jurors were watching the video in the presence of non-jurors and there was no communication with non-jurors. Even if there were error, Hollahan has not shown that he was prejudiced by the procedure employed by the circuit court. View "People v. Hollahan" on Justia Law

Named plaintiffs filed a two-count class-action complaint on behalf of “all residents of the City of Chicago who have resided in an area where the City has replaced water mains or meters between January 1, 2008, and the present.” The complaint raises claims of negligence and inverse condemnation in relation to the replacement of water meters and water main pipes, as well as the partial replacement of lead service lines that run between the water mains and residences throughout Chicago. The complaint claimed the city’s actions created an increased risk that lead will be dislodged or leach from the residents’ individual service lines. The appellate court reversed the dismissal of the complaint.The Illinois Supreme Court reinstated the dismissal. The complaint did not allege that anyone is suffering from any physical impairment, dysfunction, or physically disabling consequence caused by the city's actions. An increased risk of harm is not, itself, an injury consistent with the traditional understanding of tort law. The plaintiffs have alleged only that the replacement of water mains and meters has made the proposed class members’ property “more dangerous.” The concept of “dangerousness” is not susceptible to objective measurement and, thus, cannot by itself constitute damage under the Illinois takings clause. View "Berry v. City of Chicago" on Justia Law

In 1998, a jury convicted Stoecker of first-degree murder and aggravated criminal sexual assault of a 15-year-old girl. His convictions and sentences were affirmed. Stoecker filed numerous unsuccessful petitions for collateral relief. In 2005 Stoecker filed a petition for relief from judgment, arguing that the procedures in imposing his life sentence for murder violated the Supreme Court’s 2000 “Apprendi” holding that, other than the fact of a prior conviction, any fact that increases the penalty beyond the statutory maximum sentence must be submitted to a jury and proved beyond a reasonable doubt. Appointed defense counsel acknowledged that the Illinois Supreme Court had held that Apprendi did not apply retroactively to cases whose direct appeals had been exhausted. The petition was dismissed. Although Stoecker filed subsequent petitions claiming ineffective assistance of counsel, he did not appeal the Apprendi ruling.Seven years later, Stoecker again sought relief from judgment, raising the Apprendi issue. The appellate court affirmed the dismissal of the petition as untimely. Four years later, Stoecker again sought relief from judgment, arguing that under recent Supreme Court decisions, Apprendi applies retroactively to cases on collateral review. The state moved to dismiss the petition. Four days later, the circuit court dismissed the petition. The state was present but made no argument. Appointed counsel was apparently not notified of the proceeding. The court ruled that the state was correct as a matter of law. Stoecker filed an unsuccessful pro se motion to reconsider.The Illinois Supreme Court affirmed. Any violation of Stoecker’s due process rights was harmless because the deficiencies in the petition could not be cured. The petition was untimely, barred by res judicata, and meritless. Any deficient performance by appointed counsel did not warrant remand. View "People v. Stoecker" on Justia Law

In 2014, a $30,880 judgment covering backpay and pre-judgment interest was entered against Oakridge Nursing & Rehabilitation Center, LLC, for its age and disability discrimination against a former employee, in violation of the Illinois Human Rights Act, 775 ILCS 5/1-101. Oakridge Rehab had already gone out of business and transferred the assets and operation of its nursing home facility to Oakridge Healthcare Center, LLC in 2012. Unable to enforce the judgment against Oakridge Rehab, the state instituted proceedings to enforce the judgment against Oakridge Healthcare.The Illinois Supreme Court ruled in favor of Oakridge Healthcare, declining to adopt the federal successor liability doctrine in cases arising under the Human Rights Act. The court noted four limited exceptions to the general rule of nonliability for corporate successors and declined to apply the fraudulent purpose exception, which exists “where the transaction is for the fraudulent purpose of escaping liability for the seller’s obligations.” The court stated that it is within the legislature’s power to abrogate the common-law rule of successor nonliability or otherwise alter its standards through appropriately targeted legislation for employment discrimination cases. View "Department of Human Rights v. Oakridge Healthcare Center, LLC" on Justia Law

Deleon was charged with four counts of criminal sexual assault. The conditions of Deleon’s bond release prohibited him from contacting the victim or visiting her home, school, or workplace. Under 725 ILCS 5/112A-11.5, the State’s Attorney sought a plenary civil no-contact order prohibiting Deleon from contacting the victim, harassing or stalking her, and entering her place of employment. The circuit court orally pronounced that section 112A-11.5 was unconstitutional, both on its face and as applied; an evidentiary hearing was never held nor evidence proffered as to its unconstitutionality as applied to Deleon. The court found that the statute allows the state to make a prima facie case for the issuance of a protective order by producing the indictment without requiring the alleged victim to testify and be subject to cross-examination; that the requirement that a defendant present evidence of a meritorious defense to rebut the prima facie evidence violated constitutional protections against self-incrimination; and that the statute improperly shifts the burden of persuasion to the defense.The Illinois Supreme Court reversed. There is no basis for concluding that due process precludes the use of an indictment, alone, for restricting a defendant’s liberties before trial. The government has a substantial interest in protecting victims of sexual assault and related crimes from continued contact by the accused pending trial. The conditions of the no-contact order were relatively limited and largely identical to the restraints imposed as conditions of pretrial bond release. There is no legal compulsion for a defendant to rebut the prima facie evidence and no self-incrimination concerns. View "People v. Deleon" on Justia Law