Justia Illinois Supreme Court Opinion Summaries

Defendant pled guilty to intimidation (720 ILCS 5/12-6(a)(1)) and criminal damage to property (720 ILCS 5/21-1(1)(a)) and was sentenced to concurrent extended terms of 10 and 6 years, respectively, followed by one year of mandatory supervised release. Her sentences were to be served consecutively to any punishment she received for violating MSR in an unrelated case. She was also ordered to pay restitution. The appellate court vacated the extended-term portion of her criminal damage to property sentence, reducing the sentence for that offense to three years; found that, other than the extended-term sentencing issue, the trial court did not abuse its discretion; held that the trial court did not err in ordering her sentences to be served consecutively to any punishment for violating MSR in an unrelated case; and vacated the restitution order because the trial court failed to admonish her about the possibility that she would be ordered to pay restitution. The Illinois Supreme Court reversed with respect to the restitution order and otherwise affirmed. View "People v. Snyder" on Justia Law

Defendant was convicted of aggravated battery with a firearm and aggravated discharge of a firearm under an accountability theory and was sentenced to concurrent terms of imprisonment of 14 years and five years,respectively. The appellate court affirmed. The Illinois Supreme Court reversed and remanded for a new trial. Reversible error occurred when the state was allowed to impeach defendant, who testified at trial, with his prior juvenile adjudication for burglary. A juvenile adjudication is typically not admissible against a testifying defendant, and defendant did not "open the door" to admission of his juvenile adjudication. View "People v. Villa" on Justia Law

After thefts from a school office, a motion activated, wireless, digital camera concealed within a clock radio and a digital video recorder were installed. Over the weekend, the motion sensor triggered the DVR and a recording was made, which was later copied by the police. School officials identified a night watchman on the recording; he admitted to stealing cash from the office, but disagreed about the amount. When the state sought to admit the VHS tape at trial, defendant objected on foundational grounds, arguing that the video skips forward 30 seconds and the state failed to explain why the gap existed. Defense counsel also argued that it had not been shown that the camera was working properly. The trial court overruled the objection and found defendant guilty. The appellate court held that the state failed to establish even the probability that the VHS tape had not been tampered with. The Illinois Supreme Court reversed the appellate court and affirmed the conviction. The totality of the evidence demonstrated that the state laid a proper foundation for admission of the VHS tape. View "People v. Taylor" on Justia Law

Following separate convictions, the circuit court of Cook County charged the two defendants $10 each for the Arrestee’s Medical Costs Fund (medical cost assessment), 730 ILCS 125/17. Neither actually received medical services. The appellate court upheld the assessment. The Illinois Supreme Court affirmed with respect to one defendant and dismissed the other appeal. The plain language of the statute does not indicate the collection of the fee depends upon actual use for defendant's medical care. The statutory scheme requires convicted defendants to contribute to the fund because an arrestee who does use medical services while in custody is required to reimburse the county only to the extent that he or she is reasonably able to pay, leaving the fund to reimburse the county for the balance. View "People v. Jackson" 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

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