Justia Illinois Supreme Court Opinion Summaries

A 16-year-old high school student was convicted of driving under the influence (DUI) of cannabis following a bench trial in the circuit court of Lake County, Illinois. The student was also convicted of improper lane usage, possession of cannabis, and reckless conduct under local ordinances. The incident occurred during a driver's education class, where the instructor noticed erratic driving behavior and reported it to school officials. A subsequent search revealed a marijuana cigarette, and field sobriety tests conducted by a school resource officer and later at the police station indicated impairment.The student appealed to the Appellate Court, Second District, arguing that the Village of Lincolnshire improperly prosecuted him without providing proof of written permission from the State's Attorney, as required by the Illinois Vehicle Code. The student also contended that the evidence was insufficient to prove DUI beyond a reasonable doubt. The appellate court affirmed the conviction, finding no requirement for the Village to submit proof of its authority to prosecute into the trial record and determining that the evidence was sufficient to support the conviction.The Illinois Supreme Court reviewed the case, focusing on whether the Village needed to establish its written permission to prosecute in the trial record and whether the evidence was sufficient to prove the student was under the influence to a degree that rendered him incapable of driving safely. The court held that the statute did not require the Village to submit its written permission into the record and that the failure to do so did not constitute plain error. Additionally, the court found that the evidence, including testimony and field sobriety tests, supported the conviction beyond a reasonable doubt. The Illinois Supreme Court affirmed the appellate court's judgment, upholding the student's conviction. View "Village of Lincolnshire v. Olvera" on Justia Law

In 2019, Deshawn Wallace was arrested after police found a handgun in his jacket during a traffic stop. Wallace did not have a Firearm Owner’s Identification (FOID) card or a concealed carry license. He was charged with being an armed habitual criminal, among other weapon-related offenses. Wallace had prior felony convictions: a 2008 armed robbery committed when he was 17 and a 2015 unlawful use of a weapon by a felon.The Cook County circuit court denied Wallace’s motion to suppress the handgun evidence. At a bench trial, the court found Wallace guilty of all charges and merged them into a single conviction for being an armed habitual criminal, sentencing him to six years in prison. Wallace appealed, arguing the trial court erred in denying his motion to suppress and that his 2008 conviction should not count as a predicate offense for the armed habitual criminal charge because he was 17 at the time.The appellate court rejected Wallace’s arguments, affirming his conviction. The court held that the armed habitual criminal statute only requires proof of two prior qualifying felony convictions, regardless of how those offenses would be treated under current laws.The Illinois Supreme Court reviewed the case and affirmed the appellate court’s decision. The court held that Wallace’s 2008 armed robbery conviction could serve as a predicate offense for the armed habitual criminal charge. The court reasoned that the statute’s language does not incorporate the current juvenile adjudication scheme and that the legislature’s use of present tense terms does not imply such an incorporation. The court also distinguished this case from People v. Stewart, noting that the armed habitual criminal statute had not been amended to include age considerations for predicate offenses. View "People v. Wallace" on Justia Law

The defendant, Robert D. Dyas, pleaded guilty to unlawful possession with intent to deliver more than 900 grams of methamphetamine. He later moved to withdraw his plea, but the Bureau County circuit court denied the motion. Dyas filed a motion to reconsider, and while it was pending, he filed a notice of appeal. He then moved to dismiss the appeal as premature, which the appellate court granted, dismissing the appeal. The trial court subsequently denied the motion to reconsider, and Dyas appealed again. The appellate court vacated the trial court’s denial of Dyas’s motion to withdraw his guilty plea, citing non-compliance with Rule 401(a) regarding the waiver of counsel for postplea proceedings, and remanded for new postplea proceedings.The appellate court, Third District, vacated the trial court’s denial of Dyas’s motion to withdraw his guilty plea, finding that the trial court failed to comply with Rule 401(a) when accepting Dyas’s waiver of counsel for postplea proceedings. The appellate court remanded the case for new postplea proceedings.The Supreme Court of Illinois reviewed the case and found that the appellate court lacked jurisdiction over Dyas’s appeal because his notice of appeal was filed more than 30 days after the denial of his Rule 604(d) postjudgment motion. The court held that a successive postjudgment motion to reconsider the denial of a motion to withdraw a guilty plea does not toll the time for filing a notice of appeal. Consequently, the appellate court’s judgment was void. The Supreme Court vacated the appellate court’s decision and affirmed the circuit court’s judgment. View "People v. Dyas" on Justia Law

Ralph Harris was convicted in three separate cases involving murder, attempted robbery, and aggravated criminal sexual assault. He filed an omnibus motion to suppress his confessions, alleging they were obtained through physical and mental coercion by detectives. The circuit court denied the motion, finding the confessions were voluntary. Harris was convicted, and his convictions were affirmed on direct appeal.Harris then filed postconviction petitions under the Post-Conviction Hearing Act, alleging newly discovered evidence of a pattern of police torture corroborated his claims of coerced confessions. The circuit court advanced the petitions to a third-stage evidentiary hearing but ultimately denied relief, finding the new evidence did not prove his confessions were coerced. Harris appealed, and the appellate court reversed, remanding for a new suppression hearing to consider the new evidence.On remand, a new judge conducted the suppression hearing and denied Harris's coercion claim but vacated his convictions and ordered new trials, citing the potential impact of the new evidence on a jury. The State appealed, arguing the appellate court had jurisdiction to review the circuit court's order. Harris moved to dismiss the appeal, claiming it was an unauthorized interlocutory appeal.The Illinois Supreme Court reviewed the case and held that the appellate court had jurisdiction to consider the State’s appeal. The court found that the appellate court in Harris I had not vacated Harris’s convictions or ordered new trials but had remanded for a new suppression hearing. The proceedings on remand were a continuation of the postconviction proceedings, resulting in a final order from which the State could appeal. The court reversed the appellate court's dismissal and remanded for consideration of the State's appeal. View "People v. Harris" on Justia Law

Jatterius L. Yankaway was arrested on April 7, 2020, for allegedly shooting Robert Hunter on July 26, 2019. Due to the COVID-19 pandemic, the Illinois Supreme Court had tolled speedy-trial terms in criminal proceedings. On September 19, 2022, a jury found Yankaway guilty of attempted first-degree murder, aggravated battery, and unlawful possession of a weapon by a felon (UPWF). The Peoria County circuit court sentenced him to consecutive prison terms for attempted murder and aggravated battery but reserved sentencing on the UPWF conviction.On appeal, Yankaway argued ineffective assistance of counsel for failing to file a speedy-trial demand under the intrastate detainers statute, that his convictions violated the one-act, one-crime rule, and that the circuit court misapprehended the minimum sentence for attempted first-degree murder. The appellate court affirmed in part, finding no ineffective assistance as Yankaway could not show prejudice, and no plain error in sentencing. However, it vacated the aggravated battery conviction under the one-act, one-crime rule and remanded for sentencing on the UPWF conviction.The Illinois Supreme Court reviewed the case. It affirmed the appellate court's judgment regarding counsel's effectiveness but on different grounds, and it affirmed the sentencing for Yankaway’s convictions. The court found that the intrastate detainers statute did not apply to Yankaway as he was not committed to the Department of Corrections when the State proceeded on one of his charges. The court also found that defense counsel performed deficiently by failing to object to a continuance but held that this did not prejudice Yankaway as the continuance was attributable to him. The court concluded that the circuit court did not abuse its discretion in attributing the continuance to Yankaway and denying his motion to dismiss. Finally, the court found no plain error in the sentencing decision. The part of the appellate court judgment remanding for sentencing on the UPWF conviction was vacated. View "People v. Yankaway" on Justia Law

Travaris T. Guy was convicted of attempted first degree murder and second degree murder for the shooting of David Woods Sr. and Sheena Woods. The jury found that Guy acted with the intent to kill but also believed his actions were lawfully justified, which led to an inconsistent verdict. Guy did not raise this issue on direct appeal or in his initial postconviction petition but later filed a successive postconviction petition claiming inconsistent verdicts and ineffective assistance of counsel.The Will County circuit court denied relief on the inconsistent verdict claim but granted a new trial on a separate claim. The appellate court reversed Guy’s attempted first degree murder conviction, holding that the jury instruction misstated the law, the conviction was inconsistent with the second degree murder conviction, and the jury’s finding of self-defense precluded a guilty verdict for attempted first degree murder.The Illinois Supreme Court reviewed the case and affirmed the appellate court’s judgment in part, reversed in part, and remanded to the circuit court to sentence Guy on the lesser-included offense of aggravated battery with a firearm. The court held that a conviction for attempted first degree murder requires proof of intent to kill without lawful justification. The jury instruction was erroneous as it only required intent to kill. The jury’s finding that Guy believed in the need for self-defense was incompatible with the intent required for attempted first degree murder. The court also found that Guy’s attorneys were ineffective for failing to properly raise these issues. View "People v. Guy" on Justia Law

Michael Williams pled guilty to two counts of aggravated battery with a firearm and was sentenced to two consecutive 10-year terms. Williams later filed a postconviction petition alleging ineffective assistance of counsel, claiming his trial counsel allowed the trial judge's son to participate in a pre-plea meeting. The circuit court dismissed the petition at the second stage of postconviction proceedings.The appellate court reversed the circuit court's dismissal, finding that Williams's postconviction counsel provided unreasonable assistance by failing to adequately support the claim of ineffective assistance of trial counsel. The appellate court remanded the case for further second-stage proceedings with new counsel.The Illinois Supreme Court reviewed the case and reversed the appellate court's decision. The Supreme Court held that Williams's postconviction counsel did not provide unreasonable assistance. The court noted that the postconviction petition survived the first stage and was not found deficient or frivolous by the trial court. The Supreme Court found no evidence in the record to suggest that additional facts or arguments could have been included in the petition to support Williams's claim. The court concluded that the arguments made by postconviction counsel were the best options available under the circumstances, even if they were ultimately unsuccessful. The Supreme Court affirmed the circuit court's judgment dismissing Williams's postconviction petition. View "People v. Williams" on Justia Law

The defendant, Kendall Cecil Morgan, was charged with home invasion and domestic battery for allegedly entering Vanessa Williams' apartment without authority and striking her in the face. The State filed a petition to deny Morgan pretrial release, citing the charges and arguing that his release posed a threat to the community. At the detention hearing, the State presented evidence of the charges and Morgan's criminal history, including a previous conviction for armed robbery and pending cases for DUI and battery. The defense argued that Morgan had been diagnosed with bipolar disorder and suggested conditions like electronic monitoring and mental health treatment.The McLean County Circuit Court found that the State had established by clear and convincing evidence that Morgan committed the offenses, posed a threat to the community, and that no conditions could mitigate his dangerousness. The court granted the State's petition to deny pretrial release. Morgan appealed, arguing that the State had not met its burden and that the appellate court should review the circuit court's decision de novo.The Illinois Appellate Court reviewed the circuit court's decision for an abuse of discretion and upheld the denial of pretrial release. The appellate court reasoned that the circuit court's ability to observe the defendant warranted deference, even when the evidence was presented by proffer.The Illinois Supreme Court reviewed the case to determine the appropriate standard of review for pretrial detention decisions under section 110-6.1 of the Code of Criminal Procedure. The court held that when live testimony is presented, the circuit court's decision should be reviewed under the manifest weight of the evidence standard. However, when the parties proceed solely by proffer, the reviewing court should conduct a de novo review. Applying de novo review, the Supreme Court affirmed the circuit court's judgment denying Morgan pretrial release. View "People v. Morgan" on Justia Law

The defendant was convicted of unlawful possession of a controlled substance after a stipulated bench trial. The conviction stemmed from evidence found in a locked kitchen cabinet during a warrantless search by police officers who were investigating a gas leak in the defendant's home. The defendant filed a motion to suppress the evidence, arguing that the search was unreasonable and violated the Fourth Amendment. The trial court denied the motion, and the defendant was subsequently convicted.The Second District Appellate Court affirmed the conviction, holding that the police officers' actions were permissible under the community caretaking or emergency aid exceptions to the warrant requirement. The appellate court found that the use of a flashlight to look into the cabinet did not constitute a search under the Fourth Amendment. One justice dissented, arguing that the use of the flashlight to peer into a locked cabinet was a search in violation of the Fourth Amendment.The Supreme Court of Illinois reviewed the case and reversed the lower courts' judgments. The court held that the contraband found in the locked cabinet was not in plain view and that the police officers' actions constituted an unreasonable search. The court concluded that the use of a flashlight to look into the cabinet, which was secured with a chain and padlock, amounted to a search that was not justified by the emergency aid or community caretaking exceptions. As a result, the trial court erred in denying the defendant's motion to suppress the evidence. The Supreme Court reversed the defendant's conviction and vacated his sentence. View "People v. Hagestedt" on Justia Law

The case involves the transition from a pretrial system with monetary bail to one without it, as per amendments to the Illinois Code of Criminal Procedure. Damarco Watkins-Romaine, charged with multiple serious offenses, was ordered released pending trial with a $350,000 bail, which he could not pay. After the amendments abolishing monetary bail took effect, he petitioned for release, arguing that the financial condition was improper. The State responded with a petition to detain him under the new Code.The Cook County circuit court denied Watkins-Romaine's petition for release. The appellate court reversed this decision, holding that the legislature did not intend to allow the State to file a petition for pretrial detention under these circumstances and that the State's petition was untimely.The Illinois Supreme Court reviewed the case and reversed the appellate court's decision. The Supreme Court held that the State may file a petition to detain a defendant pretrial in response to a defendant’s petition to remove the condition of monetary bail, even if the defendant had been ordered released but could not satisfy the previously set monetary bail. The court found that the procedures followed in the circuit court were fair and consistent with the amended Code. The case was remanded to the appellate court to consider Watkins-Romaine's remaining contentions. View "People v. Watkins-Romaine" on Justia Law