Justia Illinois Supreme Court Opinion Summaries

Marathon Petroleum Company LP (Marathon) was audited by the Cook County Department of Revenue (Department) for gasoline and diesel transactions between January 2006 and July 2014. The Department determined that Marathon failed to collect and remit taxes on certain transactions, specifically "book transfers," and assessed taxes, interest, and penalties. Marathon argued that these transactions were financial settlements of forward contracts, not taxable sales, and sought administrative review.An administrative law judge (ALJ) upheld the Department's assessments, finding that Marathon did not provide sufficient documentary evidence to prove that the book transfers did not involve a change of ownership or movement of fuel. Marathon then sought judicial review, and the circuit court reversed the ALJ's decision, finding that the Department's assessments were unreasonable and that Marathon had provided sufficient evidence to rebut the Department's prima facie case.The appellate court reversed the circuit court's decision, affirming in part the ALJ's decision and remanding for a recalculation of the amount due. The appellate court held that the Department's auditing method was reasonable and that Marathon did not meet its burden of rebutting the Department's prima facie case. The appellate court also found that the transfer of an intangible ownership interest was enough to make the book out transactions taxable.The Supreme Court of Illinois reviewed the case and found that the ALJ misunderstood some of the evidence presented by Marathon. The court held that Marathon provided sufficient documentary evidence to rebut the Department's prima facie case and that the ALJ's conclusion was clearly erroneous. The court reversed the appellate court's judgment, affirmed in part and reversed in part the circuit court's judgment, and remanded the case to the Cook County Department of Administrative Hearings for further proceedings to determine if the Department can prove its case of taxability under the Fuel Tax Ordinance. View "Marathon Petroleum Co. LP v. Cook County Department of Revenue" on Justia Law

The defendant was convicted by a jury of aggravated domestic battery for strangling Lacey S., a family or household member. The circuit court of Logan County sentenced the defendant to an extended-term of 10 years’ imprisonment after considering statutory factors in mitigation and aggravation. The appellate court found that the defendant forfeited his argument on appeal that the circuit court considered improper factors in aggravation when imposing the sentence. The appellate court concluded that although a clear or obvious error occurred, plain error was not established because the evidence was not closely balanced, nor was the error so egregious that it denied the defendant a fair sentencing hearing. The appellate court affirmed the judgment of the circuit court.The Supreme Court of Illinois reviewed the case to determine whether the forfeited error of the circuit court’s consideration of an improper factor in aggravation at sentencing is subject to plain error review under the second prong of the plain error rule. The court found that the circuit court committed a clear or obvious error by considering the defendant’s position of trust in relation to the victim as a statutory factor in aggravation. However, the court concluded that this error did not constitute structural error, which would render the sentencing hearing fundamentally unfair and undermine the integrity of the judicial process.The Supreme Court of Illinois held that the forfeited error of considering the improper factor in aggravation is not subject to review under the second prong of the plain error rule but is subject to first prong plain error analysis. The court affirmed the judgment of the appellate court, which had affirmed the judgment of the circuit court. View "People v. Johnson" on Justia Law

An Illinois attorney, employed by the Property Tax Appeal Board (PTAB) from 2000 to 2020, filed a defamation lawsuit against Sun-Times Media Holdings, LLC, and Tim Novak. The lawsuit stemmed from articles published in February and October 2020, which alleged that the attorney pressured PTAB staff to reduce property taxes on Trump Tower due to political motivations. The articles claimed the attorney was under investigation for these actions, which the attorney contended were false and damaging to his reputation.The Cook County Circuit Court denied the defendants' first motion to dismiss, finding that the attorney had adequately pled the falsity of the statements and special damages. The court also found that the fair report privilege and actual malice were questions of fact. The court dismissed the intentional infliction of emotional distress count but allowed the defamation and false light claims to proceed.Defendants then filed a second motion to dismiss, arguing the lawsuit was a Strategic Lawsuit Against Public Participation (SLAPP) under the Illinois Citizen Participation Act. The circuit court denied this motion, finding the defendants failed to show the lawsuit was solely based on their protected political speech activities and that the attorney's claims were meritless and retaliatory.The Illinois Appellate Court affirmed the circuit court's decision, applying the Sandholm v. Kuecker test. The appellate court found that the defendants did not meet their burden to show the articles were published in furtherance of their rights to participate in government and that the attorney's lawsuit was solely based on these rights.The Illinois Supreme Court affirmed the appellate court's judgment, holding that the articles did not constitute acts in furtherance of government participation and thus were not protected under the Citizen Participation Act. The case was remanded to the circuit court for further proceedings. View "Glorioso v. Sun-Times Media Holdings, LLC" on Justia Law

Joseph Rothe was convicted of armed robbery with a dangerous weapon other than a firearm and sentenced to life imprisonment. He filed a pro se petition for relief from judgment, arguing that his conviction violated the proportionate penalties clause of the Illinois Constitution because the elements of armed robbery with a weapon other than a firearm and armed violence with a Category III weapon are identical, but the penalties are different. The Madison County circuit court dismissed his petition as untimely.The appellate court affirmed the dismissal but on different grounds. It held that the petition was timely because constitutional challenges can be raised at any time. However, it rejected Rothe’s claim on the merits, ruling that the offenses do not have identical elements because they define "dangerous weapon" differently. The appellate court concluded that the armed robbery statute's broad definition of dangerous weapons is distinct from the specific list of Category III weapons in the armed violence statute.The Supreme Court of Illinois reviewed the case and affirmed the appellate court's judgment. The court held that the definition of "dangerous weapon" under the armed robbery statute is broader than the defined list of Category III weapons in the armed violence statute. Therefore, the two statutes do not contain identical elements, and Rothe's claim that his conviction violated the proportionate penalties clause was without merit. The court concluded that the armed robbery and armed violence statutes are not identical offenses, and there was no violation of the proportionate penalties clause. The dismissal of Rothe’s petition was affirmed. View "People v. Rothe" on Justia Law

The defendant, Earl Ratliff, was indicted for robbery after allegedly taking a woman's purse by force. During his arraignment, he was informed of the charges, the sentencing range, and his right to counsel, and a public defender was appointed. Later, Ratliff expressed a desire to represent himself, and the court allowed this without providing the required admonishments under Illinois Supreme Court Rule 401(a). Ratliff eventually entered an open guilty plea and was sentenced to 15 years in prison. He later filed a pro se motion to withdraw his guilty plea and requested a private attorney. The court reappointed the public defender, who filed a motion to reconsider the sentence, which was denied.The appellate court affirmed Ratliff's conviction and sentence, despite his argument that the trial court failed to comply with Rule 401(a) before accepting his waiver of counsel. The appellate court acknowledged the trial court's omission but concluded that the defendant's waiver was knowing and voluntary, and any deficiency in the court's admonishment was harmless.The Supreme Court of Illinois reviewed the case and found that the appellate court lacked jurisdiction to review the trial court's order entering judgment on the guilty plea, as the defendant's notice of appeal only specified the order denying the motion to reconsider the sentence. The Supreme Court held that Ratliff waived any Rule 401(a) claim by pleading guilty and failing to raise the issue in his postplea motions. Additionally, the court determined that a Rule 401(a) violation is not akin to structural error and is not cognizable as second-prong plain error. Consequently, the Supreme Court vacated the appellate court's judgment and affirmed the circuit court's judgment. View "People v. Ratliff" on Justia Law

In October 2019, Alvin Brown pleaded guilty to driving while his license was revoked, a Class 2 felony, and was sentenced to nine years in prison as a Class X offender due to his criminal history. Brown later filed a postplea motion, which was denied by the Boone County circuit court. The appellate court affirmed the decision.Brown appealed, arguing that he should benefit from a new Class X recidivism provision that took effect after his sentencing but before the circuit court ruled on his postplea motion. He also claimed that his defense counsel failed to comply with Illinois Supreme Court Rule 604(d). The appellate court found that the doctrine of invited error precluded Brown's claim regarding the new statute and that his counsel was not ineffective. The court also found that defense counsel's Rule 604(d) certificate was facially compliant and that Brown had been afforded a full and fair opportunity to present his motion for reconsideration of his sentence.The Supreme Court of Illinois affirmed the appellate court's judgment. The court held that the legislature clearly intended the amendment to section 5-4.5-95(b) to apply prospectively, as indicated by the delayed implementation date. Therefore, Brown was not entitled to be sentenced under the amended statute. The court also found that Brown's counsel was not ineffective for failing to argue for the application of the new statute. Additionally, the court determined that Brown had been given a full and fair opportunity to present his postplea claims, and further postplea proceedings were unnecessary. View "People v. Brown" on Justia Law

The case involves a wrongful-death lawsuit filed by the executors and an independent administrator of the estates of deceased residents of a nursing home, Geneva Nursing and Rehabilitation Center, LLC, doing business as Bria Health Services of Geneva. The plaintiffs allege that Bria negligently and willfully failed to control the spread of COVID-19, leading to the deaths of the decedents between March and May 2020. The complaints assert that Bria's failure to quarantine symptomatic staff and residents and to implement effective hygiene and equipment procedures caused the decedents to contract COVID-19 and die from related complications.The Kane County Circuit Court denied Bria's motions to dismiss the negligence claims but allowed Bria to file a motion to certify a question for interlocutory appeal. The certified question was whether Executive Order 2020-19 provided blanket immunity for ordinary negligence to healthcare facilities that rendered assistance to the State during the COVID-19 pandemic. The appellate court modified the question to clarify that the immunity in question derived from section 21(c) of the Illinois Emergency Management Agency Act and answered the modified question affirmatively, stating that Bria would have immunity from negligence claims if it could show it was rendering assistance to the State during the pandemic.The Supreme Court of Illinois reviewed the case and agreed with the appellate court's modification of the certified question. The court held that Executive Order 2020-19, which triggered the immunity provided in section 21(c) of the Act, grants immunity for ordinary negligence claims to healthcare facilities that rendered assistance to the State during the COVID-19 pandemic. The court affirmed the appellate court's judgment and remanded the case to the circuit court to determine whether Bria was indeed rendering such assistance. View "James v. Geneva Nursing & Rehabilitation Center, LLC" on Justia Law

Anthony Harvey was arrested and charged with misdemeanor unlawful use of a weapon for possessing a firearm on a public street without a concealed carry license (CCL). During a traffic stop, police officers observed Harvey making furtive movements and later found a firearm in the van where he was seated. Harvey admitted to the officers that he did not possess a CCL or a Firearm Owner Identification card (FOID card).The Circuit Court of Cook County found Harvey guilty based on the evidence of his constructive possession of the firearm and his admission of not having a CCL. Harvey was sentenced to 30 days in jail. On appeal, Harvey argued that the State failed to establish the corpus delicti of the offense because his lack of a CCL was only proven by his own out-of-court statements. The Appellate Court affirmed the conviction, finding sufficient evidence of constructive possession and corroboration of Harvey’s lack of a CCL through his behavior during the traffic stop.The Supreme Court of Illinois reviewed the case and affirmed the lower court's decision. The court held that the State was required to prove that Harvey did not have a valid CCL to sustain the conviction under the unlawful use of a weapon statute. The court found that Harvey’s admission to the police officers that he did not have a CCL was sufficient evidence, and it did not require independent corroboration under the corpus delicti rule. The court concluded that the evidence was sufficient to support Harvey’s conviction. View "People v. Harvey" on Justia Law

The case involves the dismissal of a grand jury indictment against the defendant, who was charged with two counts of criminal sexual assault. The charges stemmed from an incident where the defendant allegedly had non-consensual sexual intercourse with the victim, Jane Doe, who was reportedly too intoxicated to give consent. The State presented the grand jury with testimony from Detective Vince Kelly, who recounted Doe's report of the events and the defendant's admission to having sex with Doe, which he claimed was consensual.The Winnebago County Circuit Court dismissed the indictment with prejudice, concluding that Kelly's testimony before the grand jury was misleading. The court found that Kelly's answers to a grand juror's questions falsely suggested that the defendant had confessed to the assaults. The court also noted that the prosecutor failed to clarify Kelly's misleading testimony. The Appellate Court affirmed the dismissal, agreeing that the misleading testimony violated the defendant's due process rights and caused actual and substantial prejudice.The Supreme Court of Illinois reviewed the case and reversed the lower courts' decisions. The court held that the record did not unequivocally establish a due process violation. The court found that the grand juror's questions were vague and could be interpreted in multiple ways, and Kelly's responses were not necessarily misleading. The court also determined that the State had presented sufficient probable cause evidence to support the indictment, independent of the allegedly misleading testimony. Therefore, the dismissal of the indictment was unwarranted. The case was remanded for further proceedings on the grand jury's bill of indictment. View "People v. Basile" on Justia Law

In this case, the defendant was convicted of first-degree murder, aggravated discharge of a firearm, conspiracy to commit aggravated discharge of a firearm, and two counts of perjury following a bench trial in the Circuit Court of Jackson County. The charges stemmed from a shooting incident in which the defendant was injured and subsequently treated in a hospital trauma room. The defendant filed a motion to suppress evidence, arguing that the police violated his Fourth Amendment rights by seizing his clothing from the trauma room without a warrant. The trial court denied the motion, finding that the clothing was in plain view and that the defendant had consented to the seizure.The Appellate Court, Fifth District, affirmed the trial court's decision to deny the motion to suppress but vacated the defendant's conspiracy and one perjury conviction. The appellate court addressed the defendant's new argument that he had a reasonable expectation of privacy in the trauma room, ultimately finding that he had forfeited this issue by raising it for the first time in his motion for a new trial. However, the court chose to address the issue and concluded that the defendant did not have a reasonable expectation of privacy in the trauma room.The Supreme Court of Illinois reviewed the case and affirmed the appellate court's judgment. The court held that the defendant did not meet his burden of establishing a reasonable expectation of privacy in the trauma room. The court considered factors such as ownership, legitimate presence, possessory interest, prior use, ability to control or exclude others, and subjective expectation of privacy. The court found that the defendant had no ownership or possessory interest in the trauma room, did not introduce evidence of the ability to exclude others, and failed to demonstrate a subjective expectation of privacy. Consequently, the trial court's denial of the motion to suppress was upheld. View "People v. Turner" on Justia Law