Justia Illinois Supreme Court Opinion Summaries

Plaintiffs' 1993 Lincoln Town Car was hit while stopped. A pipe wrench in the trunk penetrated the gas tank. The car burst into flames. Husband was killed, wife was severely injured. A jury awarded wife compensatory damages totaling $23.1 million and punitive damages of $15 million and awarded compensatory damages to the estate in excess of $5 million. The appellate court affirmed. The Illinois Supreme Court reversed. The duty analysis in a negligent-product-design case encompasses a risk-utility balancing test. Compliance with industry standards (NHTSA) is a relevant, but not dispositive. Plaintiffs presented insufficient evidence that Ford breached its duty of reasonable care on three negligent-design theories. Balancing foreseeable risks and utility factors, plaintiffs failed to present sufficient evidence that, at the time of manufacture, Ford's conduct was unreasonable or that it had acted unreasonably in failing to warn about the risk of trunk contents puncturing the tank. There was no evidence of a feasible shield that would have prevented this injury. Plaintiffs' fourth theory, premised on a postsale duty to warn, was not cognizable under Illinois law and its voluntary undertakings with respect to law enforcement vehicles did not create a duty to civilian customers. View "Jablonski v. Ford Motor Co." 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

In 2003, wife filed domestic battery charges against husband; he was found not guilty and filed for dissolution. At a 2005 hearing on a motion to modify temporary child support, the judge stated that the parties had been before him in the domestic battery case. Neither lawyer objected. Nearly a year later, husband sought substitution of judge, asserting bias. Wife testified that she worked part-time at a fitness club where the judge was a member, but had only said "hello," twice, in passing; husband testified that wife had indicated that she was "taking care of" the judge and that the judge had disclosed that wife had approached him several times. The petition was denied for lack of proof of actual prejudice. The appellate court and highest court affirmed. The "actual prejudice" standard was properly applied; a proposed "appearance of impropriety" standard would encourage judge-shopping. A litigant is entitled to one automatic substitution if requested before trial or hearing begins and before the assigned judge has ruled on any substantial issue, 735 ILCS 5/2–1001(a)(2)(ii). After a substantive ruling, however, (a)(3) requires substitution only when cause exists. The statute does not define "cause," but recusal is required when the probability of actual bias is too high to be constitutionally tolerable. View "O'Brien v. O'Brien" on Justia Law

Taxpayers challenged three substantive bills and one appropriation bill, part of capital projects, signed by the governor in July 2009. The appellate court held that Public Act 96–34 violated the single-subject clause of the Illinois Constitution, and that the other acts were invalid because they were contingent on enactment of Public Act 96–34. The supreme court reversed, reinstating the trial court's dismissal. All of the substantive provisions in Act 96–34 are connected to capital projects; they establish revenue sources to be deposited into the Capital Projects Fund or are related to the overall subject of the Act in that they help implement other provisions. The court upheld the other acts against single-subject challenges, including challenges based on the contingency clauses. Nothing in the state constitution prohibits making legislation contingent on a separate legislative enactment. The enactments did not violate the separation of powers doctrine, public funds clause, uniformity clause, or run afoul of constitutional veto procedures. An enactment that authorizes expenditure of public funds for a public purpose is not unconstitutional for incidental benefit to private interests. There is nothing constitutionally impermissible about the inclusion of the "as approximated below" language. View "Wirtz v. Quinn" 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

In 1996 the plaintiff, a sergeant with the forest preserve district police, was indicted for unauthorized purchase of badges and suspended without pay. The district did not respond to his inquiry about a hearing. After the criminal charges were dismissed in 2001, plaintiff requested reinstatement and back pay. The district responded that it was seeking discharge based on rules violations. Plaintiff disputed the charges and asserted that the suspension violated the rules. The employee appeals board declined to hear the matter. At a predisciplinary hearing, a three-member panel of district supervisors refused to answer questions about which rules applied to the suspension. After a hearing before the employee appeals board that concluded in 2004, plaintiff was discharged and his claim of unlawful suspension was found to be forfeited. The circuit court affirmed. The appellate court vacated. The Illinois Supreme Court reversed and remanded, rejecting the appellate court's determination that the board lacked jurisdiction. View "Genius v. County of Cook" 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