Justia Illinois Supreme Court Opinion Summaries

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

Chaudhary arrived in the U.S. from Pakistan in 2007-2008. She married Ramzan while in Pakistan. They have three children together. Ramzan also has a daughter from a different marriage. In 2012, Chaudhary divorced Ramzan. She moved to West Chicago (White Oak address). Chaudhary received Supplemental Nutrition Assistance Program (SNAP) benefits for herself and her three children. He separately received benefits for himself and his daughter. Under separate accounts, Chaudhary and Ramzan received SNAP benefits from May 2015-December 2017, both listing the White Oak address as their SNAP benefits mailing address. In 2019, the Department of Human Services investigated Chaudhary under the Illinois Public Aid Code (305 ILCS 5/12-4.4) and determined that she received overpayments totaling $21,821. The Department began an overpayment collection process. Chaudhary filed an agency appeal. The ALJ and the Secretary of Human Services upheld the determination.The circuit court reversed. The appellate court and Illinois Supreme Court affirmed. Chaudhary, as a SNAP recipient, having been previously approved and awarded SNAP benefits, was not required to prove the absence of an overpayment. The Department’s evidence was not sufficiently authenticated and does not support the determination that Ramzan resided at White Oak during the overpayment period. The Secretary’s credibility determination was unreasonable and not supported by the record. View "Chaudhary v. Department of Human Services" on Justia Law

A 1998 Chicago ordinance includes procedures, penalties, and fees that apply to vehicle owners when a vehicle has been impounded because of its use in certain municipal code offenses. Within 15 days of the impoundment, an owner may request a preliminary hearing, at which an administrative law officer determines whether there is probable cause to believe the vehicle was used in an enumerated offense. If the officer finds probable cause, the owner may regain possession of the vehicle by paying the administrative penalty applicable to the municipal code offense, plus towing and storage fees. If probable cause is lacking, the vehicle is returned to the owner; no penalty or fees are owed. An administrative penalty constitutes a debt that may be enforced as a judgment.Illinois Vehicle Code, section 11-207 provides that while local authorities can adopt additional traffic regulations, “no local authority shall enact or enforce any ordinance rule or regulation in conflict with the provisions of this Chapter unless expressly authorized herein.” Home rule units, such as Chicago, cannot adopt inconsistent local police regulations. In 2012, the Vehicle Code was amended to authorize municipalities to “provide by ordinance procedures for the release of properly impounded vehicles” and to impose “a reasonable administrative fee related to … administrative and processing costs.”The appellate court and Illinois Supreme Court affirmed the dismissal of a purported class action challenging the ordinance. A home rule unit’s imposition of penalties does not interfere with and is not inconsistent with state efforts to allow municipalities to recoup the remedial costs incurred by an impoundment. The imposition of the penalty is a valid exercise of Chicago’s home rule authority and does not constitute a criminal penalty for purposes of double jeopardy. View "Lintzeris v. City of Chicago" on Justia Law

Davidson was charged with aggravated battery (720 ILCS 5/12-3.05(d)(4)(i)), for pushing Correctional Officer Stitt in the chest. Stitt was on duty at the Montgomery County Jail when he heard loud banging, investigated, and noticed that a dry-erase board had been knocked off the wall. Stitt then saw Davidson screaming and swearing. Stitt explained that any yelling at the jail needed to be stopped immediately to reduce the likelihood of escalation among the inmates. Davidson refused to comply. Stitt informed him that he would be placed on lockdown. Davidson stated Stitt “would have to make [him] go on lockdown.” As Stitt attempted to block Davidson from running. Davidson shoved Stitt in the chest. Stitt, who was not injured, subdued Davidson. Stitt did not testify that he felt insulted or provoked by Davidson’s push. Davidson admitted to yelling and running away from Stitt. He denied hitting Stitt.The appellate court and Illinois Supreme Court affirmed Davidson's conviction. The trier of fact must consider the context of the conduct when determining whether the contact was insulting or provoking. The physical contact was precipitated by Davidson’s intentional disregard of Stitt’s commands and taunting of Stitt; it would be reasonable for the jury to infer that Davidson’s act was insulting or was provoking a physical altercation. The state is not required to prove that a battery victim subjectively felt insulted or provoked by the contact but need only prove that a reasonable person would have felt insulted or provoked by the physical contact. View "People v. Davidson" on Justia Law

In 2011, police officers stopped Villareal while he was driving a car the officers believed had been involved in a neighborhood shooting. During the traffic stop, officers searched the car and recovered a fully loaded handgun. Villareal was charged with several offenses related to the firearm. Villareal pleaded guilty to unlawful possession of a firearm by a gang member (720 ILCS 5/24-1.8(a)(1). The circuit court sentenced Villareal to four years in prison. Villareal subsequently filed a petition, arguing his sentence was improperly increased by mandatory supervised release.The circuit court dismissed the petition. On appeal, Villareal challenged section 24-1.8(a)(1) as facially unconstitutional under the Eighth Amendment because it impermissibly criminalized his status as a gang member. He also argued that it violated substantive due process. The appellate court rejected Villareal’s Eighth Amendment challenge and declined to address the due process claim, as it was raised for the first time in Villareal’s supplemental brief.The Illinois Supreme Court affirmed. The statute is rationally related to a legitimate state interest in curbing gang violence in public places and is not unconstitutionally vague. The court noted plain language explaining when a person is an active gang member. Villareal did not allege or show all gang membership is involuntary. View "People v. Villareal" on Justia Law

In July 2017, Cross was charged with murder. He remained in custody through trial. At a preliminary hearing, the court ordered Cross to respond to the state’s motion for pretrial discovery within 30 days, with written notice of any defenses. The court granted Cross six continuances, attributing each delay to Cross for purposes of the 120-day statutory speedy-trial term. On July 16, 2018, the defense indicated "ready for trial" and demanded a speedy trial. Trial was set for September 24, 2018; the 70-day period after July 16 would be attributable to the state. On August 21, Cross first raised an alibi defense. The state argued that the alibi would have been known to Cross for a year, that the late disclosure would require further investigation, and that the time from July 16 to September 24 should be attributable to Cross The court attributed the 36-day period before August 21 to the state but attributed the subsequent 34-day period to Cross. The court set a new trial date of November 6; the delay after September 24 was attributed to the state. Defense counsel did not object to a statement that the speedy-trial term would run on November 29.On appeal following his conviction, Cross first argued that his statutory speedy-trial rights were violated. The appellate court and Illinois Supreme Court rejected his argument that there is no delay unless a trial date is postponed. Cross received effective assistance of counsel. View "People v. Cross" on Justia Law

The Chicago Sun-Times sent Cook County Health and Hospitals System a request under the Freedom of Information Act (FOIA) (5 ILCS 140/1) for information about gunshot wound patients who arrive at the defendant’s emergency rooms unaccompanied by law enforcement. The newspaper was investigating whether the defendant was meeting a requirement to notify local law enforcement when so-called “walk-in” gunshot wound patients are treated, 20 ILCS 2630/3, and asked for the “time/date” of each relevant hospital admission and the corresponding “time/date” of law enforcement notification. Cook County asserted two FOIA exemptions and withheld the records, claiming they contained personal health information prohibited from disclosure by the Health Insurance Portability and Accountability Act (HIPAA) (110 Stat. 1936) and private information barred from disclosure under FOIA. The newspaper argued that the year listed on each record was discoverable, even if the time of day, day of the month, and month were not.The Cook County circuit court granted the defendant summary judgment. The appellate court reversed and the Illinois Supreme Court agreed, holding that HIPAA and FOIA permitted the release of the year elements of the records as long as the individual identifying information was redacted, or “deidentified” to maintain patient confidentiality. View "Chicago Sun-Times v. Cook County Health and Hospital System" on Justia Law

The Northwestern Illinois Area Agency on Aging (NIAAA), sought mandamus relief against the Department on Aging. The Department had designated NIAAA as a regional administrative agency (RAA) for administering programs created by the Adult Protective Services Act. NIAAA had filed petitions for administrative hearings; the Department rejected both petitions, finding that neither presented a “contested case” for which an administrative hearing is required. The first petition requested a recall of a new Protective Act Program Services Manual. NIAAA claims that the Department retaliated by terminating its grant and its position as RAA. NIAAA requested the Department to adopt administrative rules for “contested case” hearings and to compensate NIAAA for the lost funding. In its second petition, NIAAA requested a hearing on the Department’s rejection of NIAAA’s designation of Protective Act providers.The Illinois Supreme Court reinstated the dismissal of the mandamus complaint. The Department has adopted the requested administrative rules, so those allegations are moot. The Illinois Administrative Procedure Act, 5 ILCS 100/1-1 does not require hearings on the other allegations. Nothing in the relevant statutes and regulations provides that the Department's decision regarding funding and service provider designations are to be made only after an opportunity for a hearing. Under the U.S. and Illinois Constitutions, procedural due process protections are triggered only when a constitutionally protected liberty or property interest is implicated. NIAAA does not have a constitutionally protected interest in the funding or its service provider designation. View "Nyhammer v. Basta" on Justia Law

The Condominium Property Act requires condominium unit sellers to obtain specific disclosure documents from the Association or its agent before a sale and to provide them to potential buyers on request. After entering into a standard sales contract with a potential buyer who requested those disclosures, Channon obtained them from Westward, a management agent hired by the Association’s board of managers. Westward charged $245 for the documents. Channon filed a class-action lawsuit, alleging that Westward violated section 22.1 of the Act by charging unreasonable fees for the statutorily required documents and violated the Consumer Fraud and Deceptive Business Practices Act.In response to a certified question, the Illinois Supreme Court held that section 22.1 does not provide an implied cause of action in favor of a condominium unit seller against a property manager, as an agent of an association or board of directors, based on allegations that the manager charged excessive fees for the production of information required to be disclosed under that statute. The standard for a court to imply a private right of action in a statute is quite high. That extraordinary step should be taken only when it is clearly needed to advance the statutory purpose and when the statute would “be ineffective, as a practical matter, unless a private right of action were implied.” View "Channon v. Westward Management, Inc." on Justia Law