Justia Illinois Supreme Court Opinion Summaries

Sauls was charged with predatory criminal sexual assault of a child, L.G.P., who was under 13 years of age (720 ILCS 5/11-1.40(a)(1). Sauls filed a supplemental “Brady” motion for discovery and production of documents, Illinois Supreme Court Rule 412, requesting documents pertaining to a Department of Children and Family Services (DCFS) investigation against L.G.P.'s mother, and her “live-in girlfriend” regarding allegations of abuse against the two in 2018. The state responded that it requested the documents from DCFS but was not successful in obtaining them and that it had searched police databases for reports that would satisfy the request but that it appeared no such reports existed.The trial judge directed the circuit court clerk to issue a subpoena duces tecum. DCFS moved to quash the subpoena, arguing that the records pertained to an unfounded report, which was “confidential and inadmissible under Illinois law.” Alternatively, DCFS offered to turn over the report to the court for "in camera" review. The court quashed the subpoena, without requiring production or in camera review. The appellate court affirmed Saul’s conviction and 20-year sentence. The Illinois Supreme Court reversed. The trial court erred in quashing his pretrial subpoena duces tecum without first reviewing in camera the requested discovery documents. View "People v. Sauls" on Justia Law

Pingelton was charged with criminal sexual assault on victims who were 16 years old. The emergency medicine physicians who examined the victims testified that they had no opinion as to whether either victim was sexually assaulted. The appellate court affirmed his convictions. Pingelton pro se filed a postconviction petition alleging ineffective assistance of both trial and appellate counsel, citing failure to object to the presentation of improper expert testimony by the physicians. The prosecution’s motion to dismiss was served on Pingelton’s appointed counsel. Almost two years later, postconviction counsel moved to withdraw, arguing that Pingelton’s claims could not be supported as a matter of law and that the record revealed no other meritorious issues. Pingelton requested that the court allow him to amend his petition and proceed. At a “status” hearing, the state and postconviction counsel appeared personally. Pingelton appeared via telephone. The court granted counsel’s motion to withdraw and dismissed, finding that none of Pingelton’s allegations indicated that he had received “unreasonable” assistance from his attorneys.The Appellate Court affirmed. The Illinois Supreme Court affirmed. Pingelton’s right to procedural due process was violated when the court dismissed his postconviction petition without affording him adequate notice and a meaningful opportunity to be heard. However, Pingelton’s claims lack merit, so he did not present a substantial showing of a constitutional deprivation at trial or on direct appeal. View "People v. Pingelton" on Justia Law

Collins ran from Chicago police who were approaching on the street where he was standing in a group. An officer saw him drop a handgun while running. Collins was convicted of unlawful possession of a weapon by a felon and of being an armed habitual criminal. The circuit court merged the counts and sentenced him to 90 months. Collins argued that the prosecution improperly presented audio recordings from a bodyworn camera that were subject to exclusion as hearsay statements.The Appellate Court reversed the conviction and remanded for a new trial. The Illinois Supreme Court granted the state’s petition for leave to appeal, which raised the issue of whether the Law Enforcement Officer Body-Worn Camera Act (50 ILCS 706/10-1) “provides that relevant body-worn camera recordings are admissible without limitation and, in any event, [whether] such recordings are … hearsay.” The state argued that such “audiovisual recordings are not hearsay and are admissible provided they are relevant and properly authenticated.” The court dismissed the appeal, finding that the state failed to argue the threshold question presented through its petition and upon which leave to appeal was granted. View "People v. Collins" on Justia Law

Walworth, a former stockholder, sued Mu Sigma, a privately held data analytics company, and Rajaram, the company’s founder, CEO, and board chairman, alleging that after reaping the benefits of Walworth’s $1.5 million investment and reputational capital, the defendants embarked on a fraudulent scheme to oust Walworth of its substantial ownership interest in the company.The Cook County circuit court dismissed the complaint, citing the stock repurchase agreement (SRA), which included anti-reliance and general release provisions. The appellate court reversed, holding that the anti-reliance language was ambiguous. The Illinois Supreme Court reinstated the dismissal, stating that “the broad and comprehensive release agreed to by [Walworth], a sophisticated party represented by experienced counsel, unambiguously encompasses” the unjust enrichment and breach of contract claims. The bargained-for anti-reliance provisions reflected the understanding that there may be undisclosed information but that Walworth was satisfied by the information provided. Walworth had direct access to Rajaram to negotiate the arm’s-length transaction at issue and Rajaram was not acting as a fiduciary for Walworth. A corporation owes no fiduciary duty to its shareholder and Delaware law does not impose “an affirmative fiduciary duty of disclosure for individual transactions.” View "Walworth Investments-LG, LLC v. Mu Sigma, Inc." on Justia Law

In 2016, Stewart, then 20 years old, was charged with possession of a stolen motor vehicle, a Class 2 felony. While the case was pending, Stewart turned 21. In 2017, a jury found Stewart guilty. The trial court found that Stewart was subject to mandatory Class X sentencing under section 5-4.5-95(b): When a defendant, over the age of 21 years, is convicted of a Class 1 or Class 2 felony, after having twice been convicted in any state or federal court of an offense that contains the same elements as an offense now (the date the Class 1 or Class 2 felony was committed) classified in Illinois as a Class 2 or greater Class felony and those charges are separately brought and tried and arise out of different series of acts, that defendant shall be sentenced as a Class X offender. Stewart had a 2013 conviction for residential burglary, a Class 1 felony, and a 2014 conviction for possession of a stolen motor vehicle, a Class 2 felony. The trial court found Stewart eligible for Class X sentencing and sentenced him to the statutory minimum term of six years’ imprisonment.The Illinois Supreme Court affirmed that Stewart’s first felony offense, committed when he was 17 years old, was not a qualifying offense for Class X sentencing and could not serve as a basis for Class X sentencing eligibility. View "People v. Stewart" on Justia Law

Kelan, in Missouri with an adult accomplice, allegedly took Luterman’s 2019 Volkswagen by force or the threat of force. The two drove the car into Illinois, where they were apprehended. Kelan was 16 years old. He resides in Illinois with his mother. The state filed a petition to adjudicate Kelan a delinquent minor based on the Missouri carjacking and, under Illinois law, unlawful possession of a stolen motor vehicle, aggravated unlawful use of a weapon by a person under 21, and theft.The state argued that delinquency proceedings based on out-of-state conduct are explicitly permitted under the Juvenile Court Act (705 ILCS 405/5-120). The appellate court reversed the dismissal of the charges that were based on Missouri law. The Illinois Supreme Court affirmed. Section 5-120 of the Act unambiguously authorizes delinquency proceedings against a minor in Illinois who violates another state’s law. Illinois is likely to be in a better position than any other state to ensure that family and community are involved in our juveniles’ rehabilitative process, and it may help reduce disruption to the minor’s life to receive necessary services in his home state. View "In re Kelan W." on Justia Law

In 1993, Kastman was charged with misdemeanor offenses based on acts of public indecency involving children and disorderly conduct. The state’s attorney initiated a civil commitment proceeding against Kastman under the Sexually Dangerous Persons Act (725 ILCS 205/0.01). Evidence indicated that Kastman suffered from pedophilia, antisocial personality disorder, exhibitionism, and alcohol dependency. Kastman was found to be a sexually dangerous person, and the circuit court granted the petition. In 2016, Kastman was granted conditional release from institutional care.In 2020, he sought financial assistance. Kastman asserted that he was unemployed, disabled, and could not afford his $300 monthly treatment costs and the $1800 monthly rent for housing that complied with the Sex Offender Registration Act. The circuit court of Lake County ordered the Department of Corrections to pay a portion of Kastman’s monthly expenses. The appellate court and Illinois Supreme Court affirmed. The statutes indicate that a sex offender’s ability to pay is a relevant consideration in deciding who should bear the expense of treatment costs; without a clear statutory directive, the legislature is not presumed to have intended that only financially stable individuals are eligible for conditional release. Financial instability and the need for supervision to protect the public are not the same things. View "People v. Kastman" on Justia Law

Quiroz was inside the underground subway tunnel connecting CTA stations when he fell from a recessed catwalk authorized for CTA personnel and injured himself. The area near the tracks where he fell was lit. At least two trains passed without incident. He was allegedly visible on security cameras. Another train struck Quiroz in the tunnel, causing his fatal injuries.Quiroz’s estate filed a wrongful death action, asserting that, having discovered Quiroz in a position of peril, the CTA owed him a duty of care and violated that duty by failing to notify train operators of his presence and by failing to stop train service, or, alternatively, that failure to keep a lookout for persons in the tunnel and to monitor the security cameras in real-time was willful and wanton. The CTA argued that, because Quiroz was a trespasser, it owed no duty to protect him from the open and obvious danger of a moving train.The circuit court dismissed the complaint. The appellate court reversed, finding the allegations that Quiroz was a discovered trespasser in a position of peril sufficient to establish a legally recognized duty under section 337 of the Restatement (Second) of Torts. The Illinois Supreme Court reversed. Section 337 does not apply to an open and obvious danger and no further duty was owed under the circumstances. The CTA is not an insurer of a trespasser’s safety; its focus must be on ensuring mass transit. View "Quiroz v. Chicago Transit Authority" on Justia Law

Crane filed a complaint for retaliatory discharge, alleging that his employment with Midwest was terminated after he reported numerous health and safety violations to the Illinois Environmental Protection Agency. Crane was awarded $160,000 in compensatory damages and $625,000 in punitive damages. The appellate court affirmed. After losing the underlying action and paying damages to its former employee, Midwest filed a legal malpractice complaint against its attorneys and the Sandberg law firm, alleging that the attorneys failed to list all witnesses intended to be called at trial in compliance with Illinois Supreme Court Rule 213(f), resulting in six defense witnesses being barred from testifying, and several other errors.The circuit court denied the defendants’ motion to dismiss but certified a question for immediate appeal: Does Illinois’ public policy on punitive damages and/or the statutory prohibition on punitive damages [in legal malpractice actions, 735 ILCS 5/2-1115] bar recovery of incurred punitive damages in a legal malpractice case where the client alleges that, but for the attorney's negligence in the underlying case, the jury in the underlying case would have returned a verdict awarding either no punitive damages or punitive damages in a lesser sum?” The appellate court and Illinois Supreme Court answered the question in the negative and affirmed the judgment. View "Midwest Sanitary Service, Inc. v. Sandberg, Phoenix & Von Gontard, P.C." on Justia Law

Jackson was convicted of first-degree murder and attempted armed robbery. After the jury returned its signed verdict forms in open court, Jackson’s attorney asked the court to poll the jury. The circuit court then asked 11 of the 12 jurors whether the verdicts reflected on the verdict forms were their verdicts. All of the 11 jurors who were questioned confirmed that the signed verdict forms accurately reflected their verdicts. The circuit court dismissed the jury without polling the twelfth juror. Jackson’s attorney failed to object to the error and did not include the error in a posttrial motion.Jackson raised the error for the first time on direct appeal. The appellate court held that the error in polling the jury constituted structural error that called into question the integrity of the judicial process, excused the forfeiture under the second prong of Illinois’s plain error rule, and reversed the conviction. The Illinois Supreme Court reinstated the conviction. A procedure that is not required in every criminal jury trial cannot be logically categorized as an essential element of every criminal jury trial on par with the jury trial oath; no U.S. Supreme Court precedent suggests that a criminal defendant is denied the fundamental right to juror unanimity when jury polling does not take place or when there is an error in the jury polling process. View "People v. Jackson" on Justia Law