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

The Illinois Department of Corrections sought to recover the costs of defendant’s incarceration under 730 ILCS 5/1. The circuit court entered judgment in favor of the Department for $455,203.14, but precluded the Department from satisfying any of the judgment out of money defendant had earned while working for prison industry. Those wages had already been applied to offset the cost of incarceration. The appellate court affirmed the judgment, but it reversed with respect to prison earnings. The Illinois Supreme Court reversed in part, holding that once an inmate's wages have been properly subjected to the offset provision of section 3–12–5 of the Code, the remaining wages are not subject to collection. View "People v. Hawkins" on Justia Law

In defendant's trial for criminal sexual assault, the circuit court admitted evidence that defendant had also been involved in criminal sexual assault of another woman. The court cited the Code of Criminal Procedure, 725 ILCS 5/115–7.3, permitting the evidence to show a defendant’s propensity to commit sex crimes. When defendant sought to admission of evidence of his acquittal in the prior case, the court rejected his request. Defendant was convicted and sentenced to 25 years in prison. The appellate court affirmed. The Illinois Supreme Court reversed and remanded. The statutory language permits admission of both evidence of defendant’s commission of another enumerated offense and evidence to rebut that proof or an inference from that proof. Exclusion of the acquittal evidence limited the jury’s ability to assess testimony from the victim in the earlier case and was very prejudicial to the defendant. View "People v. Ward" on Justia Law

The defendant, charged with the attempted robbery death of a cab driver, agreed to plead guilty and receive a 28-year sentence on the charge of first degree murder and a 4-year sentence on the charge of possession of contraband while in a penal institution, to be served consecutively. Before accepting defendant’s plea, the trial court admonished him that the sentencing range was 20 to 60 years’ imprisonment. The state presented a factual basis for both pleas that included use of a gun. After sentencing the court denied a motion to vacate the plea. The appellate court reversed, reasoning that defendant was subject to a mandatory 15-year enhancement for being armed with a gun, so that the mandatory minimum sentence was 35 years. The Illinois Supreme Court affirmed and remanded for trial, stating that the trial court could not impose a sentence that did not include the enhancement. View "People v. White" on Justia Law

The defendant entered a plea of guilty to a murder charge. The trial court imposed a sentence of 33 years and ordered him to pay $200 for DNA testing. The appellate court rejected an argument that the court lacked authority to impose the order because the defendant's DNA was already on file. The supreme court affirmed in all other respects, but reversed the DNA order, holding that 730 ILCS 5/5-4-3 authorizes a court to order the taking, analysis, and indexing of a qualifying defendant's DNA only if that DNA is not already in the database.

While the defendant was on probation following conviction for retail theft, police and probation officers searched his residence and found marijuana and cocaine. The trial court denied a motion to suppress, convicted the defendant of unauthorized possession, and sentenced him to two years imprisonment. The appellate court reversed. The supreme court reversed, affirming the conviction. By agreeing, in his probation order, to suspicionless searches and consenting to the use of anything found during such a search as evidence, the defendant waived his Fourth Amendment rights.

During a traffic stop, a gun was recovered from a latched compartment in the backseat armrest of defendant's car. The defendant was charged with two counts: aggravated unlawful use of a weapon based on carrying an âuncased, loaded and immediately accessibleâ firearm in his vehicle (720 ILCS 5/24â1.6) and based on carrying a firearm in a vehicle âat a time when he was not on his own land or in his own abode or fixed place of businessâ and had ânot been issued a currently valid Firearm Ownerâs Identification Card.â The jury returned a general verdict of guilty. The Illinois Supreme Court reversed and remanded. A conviction on the first count cannot be upheld because it is undisputed that the gun was contained in a latched compartment. The trial court also erred in refusing to allow the defendant to produce evidence that he had a valid Indiana FOID card. The court declined to sustain the conviction on a lesser included charge of unlawful use of a weapon because it was not clear from the general verdict that the jury concluded that the gun was loaded and accessible.

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.