Justia Illinois Supreme Court Opinion Summaries

In 2008, Graefnitz went with Wilson and Moore to buy drugs. Graefnitz was shot in the back and died from his wounds. Wilson was then 14 years old. The court granted a transfer motion, concluding that charging Wilson in the juvenile justice system “with the hope that this minor will somehow be transformed into a non-violent law-abiding citizen ready for release in society at age 21” would not serve the public interest nor the interest of justice. Wilson was convicted of first-degree murder and attempted armed robbery. In response to a special interrogatory, the jury found that Wilson did not personally discharge the weapon that caused Graefnitz’s death. The PSI consisted of more than 200 pages of reports and supporting documents, including information about Wilson’s troubled background, mental disabilities, substance abuse, criminal history, and medical diagnoses. The court sentenced Wilson to 55 years’ imprisonment for murder (which included a 15-year firearm enhancement), to be served at 100%, and a consecutive four years for attempted armed robbery.Wilson sought leave to file a successive postconviction petition challenging his sentence as violating the eighth amendment by imposing a de facto life sentence without a finding of permanent incorrigibility or specifically addressing the attendant characteristics of youth discussed in the Supreme Court’s 2012 "Miller" decision. The Illinois Supreme Court reversed a decision that vacated Wilson’s sentence. The sentencing court reviewed the entire PSI, which contained extensive evidence regarding Wilson’s developmental age, maturity, and other circumstances, and announced several times that Wilson was young. Wilson received the constitutionally required procedure under Miller. View "People v. Wilson" on Justia Law

In 1983, Prante was convicted of a strangulation murder. The appellate court rejected Prante’s claim that the state’s expert testimony concerning bite marks should not have been admitted. In 1993, Prante filed a postconviction petition, alleging ineffective assistance of counsel and a due process claim concerning “material misrepresentation of evidence” relating to blood found at the crime scene.” The circuit court dismissed the petition as untimely. In 2002, Prante filed an unsuccessful petition arguing that his sentence violated Apprendi. In 2017, Prante successfully sought DNA and fingerprint testing (725 ILCS 5/116-3). No interpretable DNA profiles were obtained, and no match was found for the fingerprint.In 2018, Prante sought leave to file a successive postconviction petition that argued actual innocence, a due process claim alleging that his trial was rendered fundamentally unfair by the admission of bite mark analysis evidence, and ineffective assistance of trial and appellate counsel. Prante asserted that recent scientific studies had discredited the forensic bite mark opinion testimony. The Illinois Supreme Court found that Prante is not entitled to file either the due process or the actual innocence claim. Without any allegation that the state knowingly used the false bite mark testimony or failed to exercise diligence to discover that the testimony was false, Prante has not pled a cognizable due process claim under Illinois law. Prante has not met the high standard for setting forth a colorable claim of actual innocence. View "People v. Prante" on Justia Law

Moore and Williams, both sentenced to life in prison without parole for separate murders committed when they were 19 years old, appealed from judgments denying them leave to file successive postconviction petitions challenging their sentences. The Fourth District affirmed the judgment against Moore; the Second District reversed the judgment against Williams.The Illinois Supreme Court held that neither Moore nor Williams sufficiently pled cause for filing their successive postconviction petitions. The Supreme Court’s 2012 Miller v. Alabama decision did not change the law applicable to discretionary sentences imposed on young adult offenders, it does not provide cause for Moore and Williams to file their proposed successive postconviction petitions. Moore failed to allege facts that could support a finding that his brain development at the time of the crime required the court to treat him as a juvenile offender. View "People v. Moore" on Justia Law

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

Walton filed a class-action complaint against his former employer, alleging that Roosevelt’s collection, use, storage, and disclosure of Walton’s and similarly situated employees’ biometric data violated the Biometric Information Privacy Act (740 ILCS 14/15(a), (b), (d). Roosevelt required those employees to enroll scans of their hand geometry onto a biometric timekeeping device as a means of clocking in and out of work. Walton alleged that he was never provided with nor signed a release consenting to the collection, storage, or dissemination of his biometric data; he had never been informed of any biometric data retention policy developed by Roosevelt; and he had never been informed of the specific purpose or length of time for which his biometric information was being stored. Roosevelt argued that Walton’s Privacy Act claims were preempted by section 301 of the Labor Management Relations Act (LMRA), 29 U.S.C. 185, because Walton was a member of a collective bargaining unit with a collective bargaining agreement (CBA).The Illinois Supreme Court affirmed the appellate court holding that section 301 preempts Privacy Act claims asserted by bargaining unit employees covered by a CBA. Noting federal precedent, the court stated that although there was no reference to biometric information in the CBA, “[t]he timekeeping procedures for workers are a topic for negotiation that is clearly covered" by the CBA and "requires the interpretation or administration of the agreement." View "Walton v. Roosevelt University" on Justia Law

Williams obtained a $4 million judgment against Kelly in March 2020 for his physical and sexual abuse of her when she was a minor. Midwest obtained a $3,484,420.70 judgment against Kelly in July 2020 for breach of a commercial real estate lease. Williams and Midwest each sought to satisfy their judgments through royalties Sony paid Kelly. Sony then held $1,544,333 in royalties due to Kelly. Williams sent via registered mail a citation to discover assets to Sony on August 17, 2020, return receipt requested. On August 19, 2020, Midwest e-mailed its citation to discover assets and also sent a copy through the regular mail. Midwest’s e-mail was directed to David Castagna, who was a member of Sony’s legal staff with whom Midwest had dealt on prior, unrelated matters. On August 24, 2020, Williams’s citation was delivered to Sony and Castagna acknowledged receipt of the email citation.The trial court found that Midwest’s lien was entitled to priority. The appellate court reversed. The Illinois Supreme Court affirmed. Email service is not a recognized method for service of a citation to discover assets to a party that has not entered an appearance. Williams’s citation was entitled to priority because it was complete four days after she mailed it based on Illinois Supreme Court Rules. View "Midwest Commercial Funding, LLC v. Kelly" 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