Justia Illinois Supreme Court Opinion Summaries

Rodney Martin worked for B.F. Goodrich Company from 1966 to 2012 and was exposed to vinyl chloride monomer until 1974. He was diagnosed with angiosarcoma of the liver in December 2019 and died in July 2020. His widow, Candice Martin, filed a civil action in November 2021, alleging that Rodney’s occupational exposure caused his illness and death. She invoked the exception in section 1.1 of the Workers’ Occupational Diseases Act to avoid its exclusivity provisions.PolyOne filed a motion to dismiss for lack of personal jurisdiction, and Goodrich filed a motion to dismiss under the exclusivity provisions, arguing that section 1.1 did not apply and that using it would infringe on their due process rights. The district court denied these motions and certified two questions for interlocutory appeal to the United States Court of Appeals for the Seventh Circuit, which then certified three related questions to the Illinois Supreme Court.The Illinois Supreme Court reviewed the case and answered the certified questions. The court held that section 1(f) of the Workers’ Occupational Diseases Act is a period of repose for purposes of section 1.1. The court also determined that section 1.1 applies prospectively under section 4 of the Statute on Statutes, meaning it applies to new actions filed after the amendment was enacted. Finally, the court found that applying section 1.1 prospectively does not violate Illinois’s due process guarantee, as defendants did not have a vested right in an exclusivity defense before the employee’s injury was discovered. View "Martin v. Goodrich Corp." on Justia Law

Rebecca Petta filed a class-action complaint in the circuit court of Champaign County against Christie Business Holdings Company, P.C., doing business as Christie Clinic. Petta alleged that Christie negligently failed to prevent unauthorized access to its business email account, which potentially exposed patients' private personal data, including Social Security numbers and health insurance information. Christie moved to dismiss the complaint, and the trial court granted the motion.The trial court found that Petta had standing due to an inference of injury from unauthorized use of her phone number and city in a loan application. However, the court dismissed the complaint for failing to state a valid claim under existing law and due to the economic loss doctrine. The appellate court affirmed the dismissal but on the grounds that Petta lacked standing, as the alleged increased risk of identity theft was too speculative and the unauthorized loan application did not involve her private personal data.The Supreme Court of Illinois reviewed the case and agreed with the appellate court. The court held that Petta's allegations of increased risk of harm were insufficient to confer standing in a complaint seeking monetary damages. The court also found that the unauthorized loan application, which used only Petta's publicly available phone number and city, was not fairly traceable to Christie's alleged misconduct. Consequently, the court affirmed the appellate court's judgment, concluding that Petta lacked standing to bring her claims. View "Petta v. Christie Business Holding Co., P.C." on Justia Law

Mike Ontiveroz filed a petition to contest the 2021 election results for village president of Glendale Heights, where Jean Kaczmarek, the Du Page County Clerk, certified the results showing Chodri Ma Khokhar winning by two votes. Ontiveroz's petition alleged election irregularities but did not include verification affidavits or an allegation that he voted in the election, as required by statute.The Du Page County circuit court dismissed the petition for lack of jurisdiction, citing the absence of verification affidavits within the statutory 30-day period. Ontiveroz later attempted to amend the petition to include the affidavits, but the court maintained its dismissal. The appellate court reversed the circuit court's decision, holding that the subsequent verification sufficed for jurisdiction and that Ontiveroz adequately alleged grounds for contesting the election results. However, the appellate court did not address the issue of whether Ontiveroz had alleged that he voted, as Kaczmarek had not raised this point.The Supreme Court of Illinois reviewed the case and held that courts have an independent duty to consider jurisdictional issues, even if not raised by the parties. The court found that Ontiveroz's petition did not meet the statutory requirements because it lacked both the verification affidavits filed within the 30-day period and the necessary allegation that he voted in the election. Consequently, the circuit court lacked subject-matter jurisdiction over the case.The Supreme Court of Illinois reversed the appellate court's judgment and affirmed the circuit court's order dismissing the petition for lack of jurisdiction. The court emphasized that compliance with statutory requirements is essential for conferring jurisdiction in election contest cases. View "Ontiveroz v. Khokhar" on Justia Law

Plaintiffs, a class of individuals, filed mortgage foreclosure complaints in Illinois circuit courts and paid "add-on" filing fees mandated by section 15-1504.1 of the Code of Civil Procedure. They challenged the constitutionality of these fees, asserting that the statute violated the free access clause of the Illinois Constitution. The Illinois Supreme Court previously agreed, declaring the statute unconstitutional and affirming an injunction against its enforcement.The Will County circuit court initially certified the class and granted partial summary judgment, finding the statute unconstitutional. The appellate court reversed, and the case was remanded. On remand, plaintiffs pursued a refund of the fees. The circuit court dismissed the refund claim, citing sovereign immunity, which bars claims against the State. The appellate court reversed, holding that the circuit court had jurisdiction under the officer-suit exception to sovereign immunity, which allows suits against state officials for unconstitutional actions.The Illinois Supreme Court reviewed the case and held that while the officer-suit exception allowed the circuit court to enjoin the enforcement of the unconstitutional statute, it did not apply to the refund claim. The court determined that the refund claim was a retrospective monetary award to redress a past wrong, which falls under the jurisdiction of the Court of Claims, not the circuit court. Consequently, the Illinois Supreme Court reversed the appellate court's judgment and affirmed the circuit court's dismissal of the refund claim. View "Walker v. Chasteen" on Justia Law

In June 2019, the Illinois General Assembly amended the Illinois Gambling Act to authorize the Illinois Gaming Board to issue six new casino licenses, including one in Waukegan. Waukegan Potawatomi Casino, LLC (Potawatomi Casino) submitted a proposal, but the City of Waukegan certified three other applicants and not Potawatomi Casino. Potawatomi Casino filed a complaint seeking to prohibit the Board from issuing a casino license due to the City's alleged noncompliance with the statute. The Cook County circuit court dismissed the complaint for lack of standing.The appellate court reversed the circuit court's decision, finding that Potawatomi Casino had standing to bring the action. The appellate court concluded that Potawatomi Casino had a legally cognizable interest in competing in a fair and lawful certification process and that the alleged injury was distinct and traceable to the City's actions. The appellate court also rejected the argument that the absence of a private right of action under the Act provided a basis to affirm the dismissal.The Illinois Supreme Court reviewed the case and reversed the appellate court's decision. The court held that the Board had jurisdiction to consider the applications once the City certified the applicants, and the license issued to Full House was not void. The court found that no effectual relief could be granted to Potawatomi Casino, rendering the appeal moot. Additionally, the court determined that Potawatomi Casino lacked standing to bring the suit because it did not have a legally cognizable interest in the casino licensing process when it filed the action. The court affirmed the circuit court's dismissal of the complaint. View "Waukegan Potawatomi Casino, LLC v. Illinois Gaming Board" on Justia Law

In 1999, Sedrick White, then 20 years old, entered a blind guilty plea to one count of first-degree murder and was sentenced to 40 years in prison by the Cook County circuit court. Over 20 years later, White filed a pro se petition for postjudgment relief under section 2-1401(f) of the Code of Civil Procedure, arguing that his 40-year sentence constituted a de facto life sentence in violation of the Eighth Amendment of the U.S. Constitution and the proportionate penalties clause of the Illinois Constitution. The circuit court denied the petition, stating that the sentence did not violate the Eighth Amendment or the proportionate penalties clause.White appealed the circuit court's decision, arguing that his 40-year sentence violated the proportionate penalties clause. The appellate court affirmed the circuit court's decision, holding that White's guilty plea waived any potential constitutional claim regarding his sentence. The appellate court also found that the circuit court did not err in failing to recharacterize White's section 2-1401 petition as a petition under the Post-Conviction Hearing Act.The Supreme Court of Illinois reviewed the case and agreed with the parties that White's blind guilty plea did not waive his constitutional challenge to his sentence. The court clarified that a defendant who enters a blind guilty plea, with no agreement as to the sentence, does not waive the right to challenge the sentence. However, the court found that White's 40-year sentence was not a de facto life sentence and was not "wholly disproportionate to the offense as to shock the moral sense of the community." The court concluded that White failed to state a meritorious claim that his sentence violated the proportionate penalties clause and affirmed the judgments of the appellate court and the circuit court. View "People v. White" on Justia Law

The case involves D.H.E., the biological father of V.S., a minor. The Cook County circuit court found V.S. neglected due to an injurious environment and dependent due to his mother's disability. Consequently, V.S. was adjudged a ward of the court, and guardianship was granted to the Department of Children and Family Services (DCFS). D.H.E. appealed, arguing that the neglect finding violated his due process rights, was against the manifest weight of the evidence, and that the court failed to provide a factual basis for its disposition.The appellate court affirmed the circuit court's adjudication and disposition orders. It found that D.H.E.'s challenges related to the neglect finding were moot because he did not also challenge the dependency finding. The appellate court also upheld the disposition order, which granted guardianship and custody to DCFS based on the finding that D.H.E. was unable to care for V.S.The Illinois Supreme Court reviewed the case and affirmed the appellate court's judgment. The court held that D.H.E.'s appeal was moot because he failed to challenge the dependency finding, which alone was sufficient to support the wardship and disposition orders. The court also found that the collateral consequences exception to mootness did not apply, as no significant collateral consequences specifically tied to the neglect finding were identified. Therefore, the court did not address the remaining issues on appeal. View "In re V.S." on Justia Law

The plaintiffs, Carmen Mercado and Jorge Lopez, filed a class action complaint against their former employer, S&C Electric Company, in the circuit court of Cook County. They alleged that S&C underpaid their overtime wages by excluding certain performance bonuses from the "regular rate" of pay used to calculate overtime. S&C argued that the bonuses were statutorily excluded from the regular rate of pay and that they had made adjusted payments to cover any alleged unpaid wages.The circuit court granted S&C's motion to dismiss the complaint with prejudice, finding that the adjusted payments satisfied the alleged underpayment. The appellate court affirmed the circuit court's judgment, agreeing that the bonuses were properly excluded from the regular rate of pay and that the adjusted payments fully compensated the plaintiffs.The Supreme Court of Illinois reviewed the case and reversed the lower courts' judgments. The court held that the performance bonuses should have been included in the regular rate of pay for calculating overtime wages. The court found that the bonuses were not gifts but compensation for services performed, and thus did not fall under the exclusion in section 210.410(a) of the regulations. Additionally, the court held that the adjusted payments did not fully compensate the plaintiffs for their statutory damages, including treble damages, monthly interest, and attorney fees, as required by section 12(a) of the Minimum Wage Law.The Supreme Court of Illinois remanded the case to the circuit court for further proceedings consistent with its opinion. View "Mercado v. S&C Electric Co." on Justia Law

On June 17, 2016, Olvan Quezada was involved in a series of events at the Briarwood Apartments in Waukegan, Illinois, which led to his arrest. Police responded to a domestic disturbance call and later heard gunshots. Quezada was found with a gun under the couch where he had been sleeping. Witnesses and police officers testified about the events, including the gunshots directed at officers and Quezada's actions. Quezada was identified by witnesses and through police investigation.The Circuit Court of Lake County convicted Quezada of attempted murder of a police officer, aggravated discharge of a firearm, unlawful possession of a firearm by a street gang member, and possession of a defaced firearm. He was sentenced to concurrent prison terms for these offenses. Quezada appealed, arguing insufficient evidence for the gang-related firearm possession charge and citing trial errors, including the admission of interrogation videos and gang evidence.The Appellate Court reversed Quezada's conviction for unlawful possession of a firearm by a street gang member due to insufficient evidence. It also reversed his remaining convictions, citing the cumulative effect of two unpreserved trial errors: the admission of the interrogation videos and gang evidence. The court found these errors collectively denied Quezada a fair trial.The Supreme Court of Illinois reviewed the case and affirmed the appellate court's decision to reverse the gang-related firearm possession conviction. However, it reversed the appellate court's decision regarding the remaining convictions. The Supreme Court held that the cumulative error doctrine could not be applied to unpreserved errors unless they collectively amounted to plain error. Since Quezada's trial counsel had acquiesced to the admission of the interrogation videos, he was estopped from challenging them as plain error. The remaining gang evidence error alone did not justify reversal. Thus, Quezada's convictions for attempted murder, aggravated discharge of a firearm, and possession of a defaced firearm were reinstated. View "People v. Quezada" on Justia Law

The defendant, Angelo Clark, was charged with multiple counts of attempted first-degree murder and aggravated battery following a gang-related shooting in 2013 that injured two people. Clark moved to quash his arrest, which was based on an investigative alert issued by the Chicago Police Department. The circuit court denied his motion, and Clark did not contest this denial further in the circuit court.In 2017, a jury in the Cook County Circuit Court convicted Clark of two counts of aggravated battery with a firearm under an accountability theory. He was initially sentenced to 46 years in prison, which was later reduced to 32 years upon reconsideration.Clark appealed, and the Appellate Court, First District, affirmed his conviction and sentence. The appellate court rejected Clark's argument that his arrest was unconstitutional because it was based on an investigative alert rather than a warrant. The court also found no plain error in the circuit court's consideration of sentencing factors for juvenile offenders, as Clark was 17 at the time of the offense.The Supreme Court of Illinois reviewed the case and affirmed the appellate court's judgment. The court held that warrantless arrests based on probable cause do not violate the Illinois Constitution, even if communicated via an investigative alert. The court also found that the circuit court had considered the relevant factors for sentencing juvenile offenders, as required by section 5-4.5-105(a) of the Unified Code of Corrections, and thus, there was no clear or obvious error in the sentencing process. View "People v. Clark" on Justia Law