Justia Illinois Supreme Court Opinion Summaries

The Supreme Court affirmed in part and reversed in part the judgment of the appellate court reversing the judgment of the circuit court granting the State's motion to dismiss Petitioner's appeal of the second-stage dismissal of his petition for postconviction relief brought under the Post-Conviction Hearing Act, holding the appellate court erred in part.Petitioner was convicted of attempted murder and sentenced to forty-eight years of imprisonment. Petitioner later filed a pro se postconviction motion alleging ineffective assistance of counsel. The circuit court advanced the petition to second-stage rulings under the Act and then granted the State's motion to dismiss. In reversing and remanding for further proceedings, the appellate court concluded that Petitioner did not receive effective assistance of retained postconviction counsel at the hearing on the State's motion to dismiss. The Supreme Court (1) affirmed the appellate court's judgment reversing the circuit court's judgment of dismissal, holding that postconviction petitioners have a right to reasonable assistance of counsel under the Act; and (2) reversed the appellate court's judgment directing the circuit court to appoint new counsel, holding that the circuit court can only make one statutory appointment. View "People v. Urzua" on Justia Law

Pinkett was charged with aggravated fleeing or attempting to elude a peace officer after he failed to stop his motorcycle in response to police sirens and lights and traveled more than 21 miles per hour over the speed limit. Pinkett was ultimately arrested inside a Walmart. In opening statements, the prosecutor said that officers would testify that at Walmart Pinkett did not ask why he was being detained. Defense counsel unsuccessfully moved for a mistrial. At trial, the issue was whether Pinkett was aware of the officers attempting to stop him; there was testimony about noise levels, Pinkett's earplugs, and the lack of a rear-view mirror on his motorcycle. The arresting officer testified that he told Pinkett, ‘We need to walk out the store without making a scene,’ and he did it with no problem.” In closing arguments, the prosecutor said: “[Pinkett] doesn’t ask why he’s being detained. ... [Pinkett] has the right to remain silent … Don’t you think a normal person would say what’s this all about.”The appellate court reversed Pinkett's conviction, finding that the circuit court erred in denying Pinkett’s motion for a mistrial because evidence of Pinkett’s silence during and after his arrest was only admissible for impeachment purposes whether the silence was before or after Miranda warnings. The Illinois Supreme Court affirmed, holding that the evidence was not so overwhelming that the error was harmless. View "People v. Pinkett" on Justia Law

When he was 17 years old, Donald incurred a cervical cord injury, which left him quadriplegic. To reduce Donald’s involuntary muscle spasms, Dr. Espinosa implanted a Medtronic SynchroMed II Infusion System, a programmable pump that delivered doses of baclofen into the intrathecal space of Donald’s spine. The pump was managed by SIU Neurology and required regular refills. A routine refill went wrong, resulting in holes in the pump. Donald died days later.In a wrongful death action, the appellate court affirmed the denial of the plaintiff’s motion under the Code of Civil Procedure, 735 ILCS 5/2-402, to convert a respondent in discovery (Dr. Bakir) to a defendant. Bakir, a pulmonary critical care specialist, was Donald’s supervising physician in the ICU.The Illinois Supreme Court reversed. The plaintiff attached a certificate of merit in which a doctor opined that, within a reasonable degree of medical certainty, Dr. Bakir deviated from the standard of care. The affidavit may not have stated the specific standard of care from which Dr. Bakir deviated, but it did provide the court with sufficient information about what Dr. Bakir failed to do based upon a reasonable degree of medical certainty—timely recognize that Donald suffered from baclofen withdrawal syndrome, timely order treatment, and timely administer that treatment. The trial court mistakenly required evidence that would establish more than a reasonable probability that the defendant could be liable. View "Cleeton v. SIU Healthcare, Inc." on Justia Law

The Village alleged that the defendants breached a 2003 recorded annexation agreement executed by the Trustee that was then the legal owner of the property, which now consists of an annexed 114-acre subdivision. The Village alleged that the defendants were subject to the annexation agreement as successors to the Trustee when they purchased undeveloped portions of the property from Plank, which had acquired the property from the Trustee. The Village alleged that the defendants refused its request for a letter of credit in the amount proportionate to the number of lots the defendants owned in the subdivision, to secure the completion of roads in the subdivision.The defendants argued that, although the annexation agreement was a covenant that ran with the land, it did not confer successor status to an entity that purchased only a portion of the property subject to annexation, as opposed to the whole of the property. The Appellate Court reversed the dismissal of the action. The Illinois Supreme Court affirmed. Reading the annexation agreement as a whole, the court found that its plain language required its provisions to be binding and enforceable on the parties’ successors. Defendants are successors in title to the landowner who agreed to those obligations. The obligations imposed upon any particular purchaser depend upon the obligations of the original developer that remain unsatisfied with respect to the specific parcel sold. View "Village of Kirkland v. Kirkland Properties Holdings Co., LLC I" on Justia Law

Illinois State Trooper Scott stopped Taylor on I-80 due to an obstructed windshield. Scott approached Taylor’s vehicle, identified himself, and informed Taylor that he would give him a warning. While Scott was preparing the warning, another officer arrived with a canine unit and walked the canine around Taylor’s vehicle. The canine alerted. Scott and the other officer asked Taylor to exit his car. Taylor refused and sped off, ultimately parking his vehicle on a country road and grabbing weapons that he had in his vehicle, an AR-15, a semiautomatic rifle, and a handgun. Taylor hid in a cornfield. Scott found Taylor’s car and exited his squad car. Taylor fired 23 shots in Scott’s direction with the AR-15 rifle. Scott was unharmed. Law enforcement officers pursued Taylor, who surrendered several hours later.Convicted of attempted first-degree murder of a peace officer, Taylor was sentenced to 30 years’ imprisonment, plus an additional 20 years for using a firearm during the commission of the offense. The Appellate Court and Illinois Supreme Court affirmed. The trial court did not abuse its discretion in denying his request for a second psychiatric evaluation to determine whether he was not guilty by reason of insanity. Taylor was not subject to an improper double enhancement when he received a 20-year sentence under the firearm enhancement of section 8-4(c)(1)(C), in addition to his 30-year sentence under subsection (A). View "People v. Taylor" on Justia Law

Chapman filed a Freedom of Information Act (FOIA) (5 ILCS 140/1) request, seeking information pertaining to the Citation Administration and Adjudication System (CANVAS) for the enforcement of parking, red-light, and speed-camera tickets. The Chicago Department of Finance denied the request, citing section 7(1)(o), which exempts: “Administrative or technical information associated with automated data processing operations, including but not limited to software, operating protocols, computer program abstracts, file layouts, source listings, object modules, load modules, user guides, documentation pertaining to all logical and physical design of computerized systems, employee manuals, and any other information that, if disclosed, would jeopardize the security of the system or its data or the security of materials exempt under this Section.” The First District affirmed an order requiring the production of the documents.The Illinois Supreme Court reversed. The requested records are file layouts under section 7(1)(o); a reasonable, commonsense interpretation of section 7(1)(o) indicates that file layouts are exempt from disclosure. While public records are presumed to be open and accessible, the legislature has specifically provided for a narrow exemption with respect to administrative or technical information associated with automated data processing operations. Section 7(1)(o)'s exemption is focused on the security of the government body’s data system, and requiring a hearing to determine whether disclosure would jeopardize the security of that system every time a file layout is requested would weaken the specific exemption. View "Chapman v. Chicago Department of Finance" on Justia Law

Hutt was convicted of obstructing justice and driving under the influence of alcohol (DUI). The Fourth District affirmed. Hutt argued that the trial court improperly denied him a jury trial in the DUI case and that the evidence was insufficient to find him guilty of obstructing justice. Hutt executed a written jury waiver and was admonished with regard to his right to a jury trial. Although all five cases against him were set for a jury trial on the day of the waiver, the written waiver did not reference the DUI case number. The pretrial conference order referenced all five case numbers, indicated that Hutt had waived a jury trial, and removed the entire cause from the jury docket. Thereafter, when all five cases were called for a status hearing, Hutt's counsel stated that Hutt had previously waived his right to a jury trial. The trial court addressed Hutt, who did not challenge the waiver but, rather, explained why he had waived his right to a jury trial. At subsequent court proceedings, Hutt never objected to a bench trial in the DUI caseThe Illinois Supreme Court affirmed Hutt’s DUI conviction but reversed his obstructing justice conviction. Hutt’s refusal or recalcitrance to comply with the police officers and the search warrant to obtain his blood or urine did not meet the definition of “conceal” for the obstruction charge. View "People v. Hutt" on Justia Law

Police executed a search warrant at a Chicago home, forcibly entering the residence after nobody answered. Inside, officers saw Ramirez descending from the second floor. Ramirez was detained but allowed to return upstairs, where he retrieved his shoes from one of the bedrooms. Police searched the house and recovered a 20-gauge Benelli shotgun, a Mossberg shotgun, a 9-millimeter handgun, and ammunition. The Benelli shotgun was recovered from under the mattress of the single bed in the room where Ramirez had retrieved his shoes. From the same bedroom, police recovered mail bearing Ramirez’s name and the home's address. Ramirez was taken into custody, provided Miranda warnings, and made a statement that he bought the Benelli shotgun from a coworker for $100.Ramirez was charged with possession of a Benelli shotgun whose serial number had been “changed, altered, removed or obliterated” (720 ILCS 5/24-5(b)). The state did not present any direct evidence that Ramirez knew that the shotgun’s serial number was defaced. Ramirez did not testify or call any witnesses. The Illinois Supreme Court reversed his conviction. Section 24-5(b)’s implied mens rea of knowledge must apply to both elements of the offense, possession and defacement. The court remanded for a new trial. At the time of trial, binding precedent from an appellate court provided that the state did not have to present evidence that a defendant knew a firearm was defaced. View "People v. Ramirez" on Justia Law

Romeoville police responded to a call that a residential security alarm had been activated. Prince came to the door and stated “Jessica” lived there but was out of town. He refused to give his name or identification. Prince was arrested and taken to the police station. Another officer remained at the residence, spoke to a friend of Jessica’s, and obtained Prince’s social media username. From this, the officer determined Prince’s name and learned there was an active warrant out for his arrest. The warrant had been issued in error and was later vacated. Prince initially refused to be fingerprinted or to take a booking photo, stating his name was “Sean Williams” and giving an incorrect birth date. Prince agreed to allow the police to fingerprint and photograph him “more than minutes,” after arriving at the station.At trial, the parties did not raise, and the court did not address “material impediment” as an element of obstruction of justice by furnishing false information (720 ILCS 5/31-4(a)(1). A jury convicted Prince. On appeal, the state conceded that the evidence presented was insufficient as a matter of law where the state offered no evidence on the “material impediment” element. The appellate court remanded for a new trial, finding double jeopardy did not bar retrial. The Illinois Supreme Court reversed. Retrial is prohibited. There was no trial error, or anything similar, that prevented the state—which bore the burden of proof—from introducing evidence on the issue of material impediment. View "People v. Prince" on Justia Law

Conway was convicted as being an armed habitual criminal following a 2015 Chicago shooting, 720 ILCS 5/24-1.7. Conway challenged the sufficiency of the evidence and the identification testimony of a police officer. The appellate court found that the evidence was sufficient to convict Conway but nonetheless reversed and remanded for a new trial due to the trial court’s pronounced bias in favor of police testimony. The court had stated: I find that the officer did have a unique opportunity to view the shooter … the officer’s testimony with regard to the identity of the shooter was in fact clear, credible, and convincing… he was not in a situation where his perception might have been affected … he is a professional … which I think is something that I can take into consideration as compared to an individual who’s never had any such training.The Illinois Supreme Court reversed in part. The trial court’s comments regarding the officer’s training related to the court’s credibility determination and as nothing else in the record indicates that the trial court displayed favoritism for police testimony. View "People v. Conway" on Justia Law