Justia Illinois Supreme Court Opinion Summaries

Addison was convicted, in absentia, of unlawful possession of a motor vehicle, unlawful possession of a converted motor vehicle, forgery, and two counts of theft, arising out of his alleged use of counterfeit money to purchase a motorcycle, and was sentenced to 15 years’ imprisonment. Having failed to appear for trial, he was subsequently arrested.Addison’s appellate counsel did not file a brief and determined that there are no meritorious issues, except concerning credit that should be applied toward the prison sentences. Addison filed a postconviction petition, contending that trial and appellate counsel were deficient. Appointed postconviction counsel filed an amended petition, alleging trial counsel was ineffective for failing to file a motion to suppress based on improper Miranda warnings, for failing to object to expert testimony regarding counterfeit currency when no expert was disclosed, and for failing to argue sufficiency of the evidence where there were discrepancies; and that the court erred in giving an accountability instruction. The petition did not assert ineffective assistance of appellate counsel. The trial court dismissed the petition.Addison appealed, arguing that postconviction counsel rendered unreasonable assistance in failing to argue ineffective assistance of appellate counsel. The Illinois Supreme Court agreed. Addison did not forfeit collateral review of his conviction by failing to appear at trial. While any postconviction claims that could have been raised on direct appeal are generally forfeited that forfeiture could have been overcome by framing the issues as ineffective assistance of appellate counsel for failing to raise the issues on direct appeal. The appellate court properly remanded for compliance with Illinois Supreme Court Rule 651(c) without considering the merits. View "People v. Addison" on Justia Law

In March 2020, the Illinois Supreme Court began entering a series of emergency administrative orders to address disruptions to the court system caused by the outbreak of the COVID-19 pandemic. Certain orders authorized the state’s circuit courts to toll the time restrictions set forth in section 103-5(a) of the Code of Criminal Procedure, 725 ILCS 5/103-5(a), the speedy-trial statute. Mayfield was tried and convicted in accordance with the administrative orders’ tolling provisions but after the speedy-trial term prescribed by section 103-5(a) had run.Mayfield argued that the court’s administrative orders violated the Illinois Constitution’s separation-of-powers clause by infringing on the General Assembly’s legislative authority. The Illinois Supreme Court affirmed his conviction. Because section 103-5(a) involves the scheduling of trials, the statute is a matter of court procedure and within the court’s constitutional authority over all state courts. Where, as here, a statute and a supreme court rule governing court procedure cannot be reconciled, the statute must give way to the rule. The orders that tolled the speedy-trial statute did not violate the separation-of-powers clause. View "People v. Mayfield" on Justia Law

After an altercation that occurred on the stoop of a residential apartment, Whitehead was convicted of two counts of aggravated battery in a place of public accommodation and sentenced to 42 months’ imprisonment. Whitehead argued that his conviction for aggravated battery should be reduced to simple battery because the offense was not committed “on or about a public place of accommodation.” The appellate court rejected Whitehead’s assertions and affirmed his conviction, finding that the stoop upon which the victim was battered was a public place of accommodation pursuant to 720 ILCS 5/12-3.05(c).The Illinois Supreme Court vacated Whitehead’s conviction for aggravated battery and ordered entry of a conviction for simple battery. The statute does not define a “public place of accommodation or amusement.” The court concluded that the language refers to a place for the use of the general public that is supplied for convenience, to satisfy a need, or to provide pleasure or entertainment. The intent of the legislature in enhancing the offense from simple battery to aggravated battery was to protect the public from increased harm in public places. In this case, there was no possibility of harm to the general public. View "People v. Whitehead" on Justia Law

After police found her severely-abused seven-year-old son alone on the streets of Chicago, Woods was convicted of four counts of aggravated battery of a child. The jury also concluded that the prosecution proved beyond a reasonable doubt that the aggravated battery was accompanied by exceptionally brutal or heinous behavior indicative of wanton cruelty. Woods’s paramour and codefendant, Richardson, was found guilty of the same offenses. Woods was sentenced to an aggregate term of 50 years.On appeal, Woods argued that the jury instructions on accountability and parental accountability were directly conflicting instructions. The appellate court and Illinois Supreme Court affirmed. Any conflict in the required knowledge element in the parental accountability instructions was harmless error because Woods’s knowledge was not an essential element. Woods and Richardson were charged jointly on the theory that they acted together to brutalize and torture the child. Woods was found guilty and does not challenge the jury instructions regarding principal liability. Woods’s liability was not based on her passive presence; the evidence of her knowledge and participation in the abuse was clear and convincing. View "People v. Woods" on Justia Law

Tompkins, convicted of unlawful use or possession of a weapon by a felon, argued that the circuit court erred in declining to give a jury instruction under the Law Enforcement Officer-Worn Body Camera Act, 50 ILCS 706/10-30, and by admitting body camera footage showing marijuana belonging to Tompkins’s co-arrestee. Tompkins argued that he was not charged with possession of the marijuana, there was no allegation he had anything to do with the marijuana, and that he would be prejudiced by playing that part of the video for the jury because it could cause an inference that the marijuana belonged to him. The footage at issue was part of a continuous video and, immediately after depicting marijuana, it depicts the gun that is the subject of Tomkins’s charge on the ground where it was located.The Illinois Supreme Court affirmed. Because Tompkins’s tendered jury instruction did not instruct the jury to consider whether an officer’s failure to activate his body camera was reasonably justified, it was not an accurate statement of the law. Any error in not giving the tendered instruction was harmless. The admission of the challenged portion of the video was error, as it was irrelevant and unduly prejudicial but the admission of such evidence was harmless, given testimony that the marijuana did not belong to Tompkins and the other overwhelming evidence of Tompkins’s guilt. View "People v. Tompkins" on Justia Law

During a pat-down search of Brown, Chicago officers recovered a loaded handgun from his pocket and packets of a suspected narcotic from the driver’s seat of his car. Brown was charged with being an armed habitual criminal and possessing a controlled substance. Two attorneys appeared on Brown’s behalf. The court questioned the venire members in panels and conferred with the attorneys at a sidebar to discuss objections. The court held eight sidebars off the record before announcing that a jury had been selected. The judge then went back on the record, outside the presence of the jury, and explained the challenges for cause and for peremptory challenges. The jury found Brown guilty of being an armed habitual criminal. In his motion for a new trial, Brown did not challenge the sidebars. On appeal, Brown argued that he was deprived of his constitutional right to be present at a critical stage of the proceeding and asserted that his defense counsel was ineffective for failing to object to the process where jurors were challenged at sidebars without Brown himself being present.The appellate court and Illinois Supreme Court affirmed his conviction. Brown did not establish prejudice; he failed to show that he was not tried by an impartial jury. Brown was present in the courtroom for all the questioning of the venire members; the record is silent as to whether Brown talked with counsel about venire members before the sidebars. Without any evidence that counsel failed to represent Brown’s interests at the sidebars, there is no basis to conclude that counsell rendered deficient performance by failing to object to the procedure. View "People v. Brown" on Justia Law

After a 2016 single-car collision, Galarza was found guilty of DUI (625 ILCS 5/11-501(a)(1)), failure to reduce speed to avoid an accident (11-601(a)), and operating an uninsured motor vehicle (3-707). The appellate court affirmed his conviction for failure to reduce speed to avoid an accident. The prosecution conceded error on the conviction for operating an uninsured motor vehicle, which was reversed. The court further determined the trial court had not been required to admonish Galarza under Rule 402(a), as his stipulated bench trial was not tantamount to a guilty plea.The Illinois Supreme Court affirmed. Viewing the stipulated evidence in the light most favorable to the state, a rational trier of fact could have found Galarza guilty beyond a reasonable doubt of failure to reduce speed to avoid an accident. A stipulated bench trial is tantamount to a guilty plea if the state’s entire case is to be presented by stipulation and the defendant does not present or preserve a defense or the stipulation includes a statement that the evidence is sufficient to convict the defendant.” If a stipulated bench trial is tantamount to a guilty plea, the court must give the defendant Rule 402(a) guilty plea admonishments. Galarza did more than deny stipulated facts, he presented a defense. View "People v. Galarza" on Justia Law

In 1993, Clark entered Catlin's Galesburg apartment to commit robbery. Clark was 24 years old; Catlin was 89. Clark killed Catlin by cutting her throat, then robbed the apartment. Clark pled guilty but mentally ill to first-degree murder and robbery. Clark suffered from antisocial personality disorder, borderline personality disorder, and fetal alcohol syndrome. He had an IQ of 79 and the intellectual ability of a 13-14-year-old; he had been severely abused as a child and had an extensive criminal history. Clark was sentenced to 90 years of imprisonment for the murder, with a consecutive 15-year prison sentence for the robbery. The appellate court affirmed. In 2001 and 2012 Clark filed unsuccessful post-conviction petitions.In a 2018 motion for leave to file a successive postconviction petition, Clark challenged the constitutionality of his sentence as inconsistent with the Illinois Constitution's proportionate penalties clause. Clark argued that his sentence was the functional equivalent of a life sentence and that the circuit court failed to give sufficient weight to the characteristics of his intellectual disabilities and his young age as mitigation factors. The appellate court and Illinois Supreme Court affirmed the denial of relief.The proportionate penalties clause requires penalties to be determined with the objective of restoring the offender to useful citizenship and provides a limitation on penalties beyond those afforded by the eighth amendment. Precedent does not establish “cause” for relaxing the res judicata doctrine with respect to the issues Clark raised, which were decided on direct appeal. Clark also cannot establish prejudice under the cause-and-prejudice test by advancing a challenge to his sentence as it relates to his intellectual disabilities. “Neurological development was not a prospect for” Clark. View "People v. Clark" on Justia Law

Heineman was the driver in a single-vehicle accident that resulted in the death of his passenger. Fisher— an officer who investigated the case—testified that he was familiar with the law and had received training on a mathematical formula for converting blood serum alcohol concentration into a whole blood equivalent. Fisher testified— over objection—that he learned of Heineman’s blood serum alcohol concentration test results and could apply the formula. He explained, “[y]ou would divide the blood serum level, which in this case is .155, by 1.18 to get a [whole blood alcohol concentration of] [.]131,” which exceeds the legal limit for DUI in Illinois. Heineman was convicted of two counts of aggravated driving under the influence of alcohol (625 ILCS 5/11-501(a)(1), (2), (d)(1)(F)).The Illinois Supreme Court reversed as to count I; the circuit court abused its discretion by admitting Fisher’s testimony regarding the conversion factor, such that the state failed to prove Heineman’s whole blood alcohol concentration was 0.08 or greater when he drove. The court affirmed on count II, in which the state was required to prove he was under the influence of alcohol when he drove. Heineman conceded that, besides his whole blood alcohol concentration, the state presented other evidence from which a reasonable trier of fact could conclude that he was driving while under the influence and that evidence could sustain his conviction on count II despite any failure to prove his whole blood alcohol concentration. View "People v. Heineman" on Justia Law

Jones was arrested following a traffic stop and was charged with unlawful possession of ammunition by a felon, 720 ILCS 5/24-1.1(a). Officer Wakeland testified that he searched the car and found two rounds of .40-caliber ammunition in the glove compartment. Jones stated that the ammunition belonged to her husband; she acknowledged that she had a 2002 felony conviction for identity theft. Jones explained that she and her husband shared a vehicle; her husband had guns and a FOID card. Her husband, Brown, testified that although the vehicle was registered in Jone's name only, he also used the vehicle and sometimes took his firearm with him. Brown identified his FOID card and the.40-caliber cartridges as his. Jones knew that Brown transported a firearm in her car. The jury was instructed that the state must prove: “That the defendant knowingly possessed firearm ammunition; and Second Proposition: That the defendant had previously been convicted of the offense of Identity Theft.” The jury asked for the definition of “knowingly.” The court responded that the word should be given its plain meaning "within the jury’s common understanding.”The appellate court and Illinois Supreme Court affirmed Jones’s conviction, rejecting a challenge to the jury instructions. Defense counsel’s strategy with respect to the jury’s question was reasonable. A rational trier of fact could have found Jones had control over the premises where the ammunition was located and could find that she knowingly possessed the ammunition. View "People v. Jones" on Justia Law