Justia Illinois Supreme Court Opinion Summaries

In this case, defendant Demetrius Gray was convicted of the offense of being an armed habitual criminal. The appellate court reversed this conviction, contending that the prosecution failed to prove that Gray had two prior qualifying felony convictions because he was 17 years old at the time of one of the alleged predicate offenses. The State appealed this decision, arguing that the evidence at trial was sufficient to prove the elements necessary to convict Gray of being an armed habitual criminal.The Supreme Court of the State of Illinois reversed the appellate court's judgment and affirmed Gray's conviction. The court found that Gray's defense counsel's stipulation that Gray had "two prior qualifying felony convictions for the purposes of sustaining the charge of armed habitual criminal" was sufficient evidence of Gray's prior qualifying convictions. Therefore, the State did not need to present further evidence in support of the stipulated fact of Gray's prior qualifying offenses. The court also rejected Gray's claim of ineffective assistance of counsel in making the stipulation as Gray could not show that, but for the deficiency in counsel's representation, there is a reasonable probability the trial result would have been different. The court concluded that a rational trier of fact could have found the essential elements of the charge of being an armed habitual criminal beyond a reasonable doubt. View "People v. Gray" on Justia Law

In this case, a minor identified as M.U., through her parents, filed a complaint against Team Illinois Hockey Club, Inc. and the Amateur Hockey Association of Illinois, Inc., alleging that they violated Section 5-102(A) of the Illinois Human Rights Act by discriminating against her due to her disability. M.U. claimed that Team Illinois excluded her from participating in its activities at Seven Bridges Ice Arena, a public accommodation, due to her mental health conditions, thereby denying her full and equal enjoyment of the facilities and services.The defendants filed a motion to dismiss the complaint, arguing that M.U.'s allegations pertained to her exclusion from the team and its activities, not a place of public accommodation. The circuit court agreed and dismissed the complaint. The appellate court, however, reversed this decision, stating that Team Illinois, by its lease and operation of Seven Bridges, could not deny M.U., based on her disability, the privilege of participation in athletic events held at places of public accommodation.The Supreme Court of the State of Illinois affirmed the appellate court's judgment. It held that the Act did not delineate between “portions” of a place of public accommodation subject to its provisions. The court noted that, while Team Illinois itself might not be a place of public accommodation, it operated within one and was thus subject to the Act. The court concluded that M.U.'s allegations were sufficient to state a cause of action under Section 5-102(A) of the Act. The case was remanded to the circuit court for further proceedings. View "M.U. v. Team Illinois Hockey Club, Inc." on Justia Law

In this case, the Supreme Court of the State of Illinois affirmed the lower courts' decisions denying Darrell Fair's claim of torture. Fair, who had been convicted of a felony, appealed the circuit court’s denial of his claim of torture under the Illinois Torture Inquiry and Relief Commission Act. The Supreme Court held that a court analyzing a claim of torture under the Act must consider the totality of the circumstances, including any allegations of constitutional violations that would not by themselves support a freestanding claim of torture under the Act. However, the court ultimately concluded that the circuit court’s determination that Fair failed to prove his claim of torture was not manifestly erroneous. The court found that Fair had not shown by a preponderance of the evidence that under the totality of the circumstances, the combination of acts alleged were sufficiently severe to constitute torture. The court emphasized the circuit court’s credibility determinations as the fact finder at the evidentiary hearing, where it found Fair to be a "wholly incredible witness," while another witness was "extremely" credible. View "People v. Fair" on Justia Law

In this case, Richard Huff, a convicted murderer serving a life sentence, filed a pro se postconviction petition alleging that his life sentence was unconstitutional under Apprendi v. New Jersey. The petition was automatically advanced to the second stage due to the time limit, and counsel was appointed. However, appointed counsel did not amend the pro se petition and instead stood on the allegations in the petition. The Cook County circuit court dismissed the petition, and the appellate court affirmed. Huff argued that his postconviction counsel provided unreasonable assistance by standing on a meritless petition, rather than moving to withdraw or amending the pro se petition. The Supreme Court of the State of Illinois held that Huff failed to rebut the presumption of reasonable assistance and affirmed the dismissal of the pro se petition. The court found no indication that Huff's postconviction counsel knew that his claim was frivolous or patently without merit. The court also noted that while Huff's claim was ultimately unsuccessful, there was no duty for his counsel to withdraw under these circumstances. View "People v. Huff" on Justia Law

In the case before the Supreme Court of the State of Illinois, the court deliberated on the admissibility of hearsay evidence under the forfeiture by wrongdoing exception. The defendant, Micheal D. Chatman, was charged with four counts of first degree murder in relation to the shooting death of Ricky Green. The State sought to introduce statements made by Dominique “Dee” Collins, who was unavailable for trial, under the forfeiture by wrongdoing exception to the hearsay rule and the sixth amendment confrontation clause. The lower court allowed Collins’s statements to be introduced, ruling him unavailable and that the State had made reasonable, good-faith efforts to secure his presence at trial. The defendant was subsequently found guilty of felony murder and sentenced to prison. The appellate court affirmed the decision. The defendant appealed, arguing the State failed to demonstrate good faith efforts to procure Collins’s presence at trial.The Supreme Court of the State of Illinois affirmed the lower courts' decisions. The court held that when the State seeks to introduce hearsay under the forfeiture by wrongdoing exception, the State must demonstrate that the witness is unavailable and that reasonable, good-faith efforts were made to procure the witness’s attendance by a preponderance of the evidence. In this case, despite Collins's intention not to be found, the court found that Detective Christian utilized the information available to him in an ongoing attempt to locate Collins, thus meeting the requirement of reasonable, good-faith efforts. Therefore, the court found no error in the admission of Collins’s statements. View "People v. Chatman" on Justia Law

This appeal arises from a prolonged divorce proceeding in Illinois. The appellant, Masud M. Arjmand, sought to dissolve his marriage to Muneeza R. Arjmand in 2009. In the course of the proceedings, the appellant filed multiple petitions for substitution of judge and a separate complaint against Morgan Stanley Smith Barney, LLC and the Stogsdill Law Firm. The circuit court dismissed the appellant's complaint with prejudice, and this dismissal order was affirmed by the appellate court based on the doctrine of res judicata.On appeal to the Supreme Court of Illinois, the main issue was whether the appellate court had jurisdiction to consider prior orders denying the appellant’s petition and motion for substitution of judge in conjunction with an appeal under Illinois Supreme Court Rule 304(a). The Supreme Court affirmed the appellate court’s judgment that it lacked jurisdiction to review the petition and motion.The Supreme Court clarified that Rule 304(a) applies exclusively to final orders and does not provide jurisdiction to review rulings on requests for substitution of judge. The Court emphasized the policy disfavoring piecemeal appeals and stated that the circuit court’s Rule 304(a) findings were limited to determining the propriety of the dismissal of the appellant’s complaint. The Court rejected the appellant’s argument that the appellate court should have considered the rulings on his substitution requests to promote judicial economy, noting that principles of judicial economy may not override the jurisdictional barrier imposed by an Illinois Supreme Court rule. View "In re Marriage of Arjmand" on Justia Law

In the state of Illinois, a group of active and retired members of local police and firefighter pension funds filed a complaint against the Governor and other officials, challenging the constitutionality of Public Act 101-610. This Act amended the Illinois Pension Code and consolidated all local police and firefighter pension fund assets into two statewide pension investment funds. The plaintiffs claimed the Act violated two provisions of the Illinois Constitution: the pension protection clause and the takings clause. They argued that the Act diminished their pension benefits by diluting their voting power and control over investment decisions, and by imposing costs associated with the Act's implementation, including repayment of any transition loans. The Supreme Court of Illinois disagreed with the plaintiffs, affirming the lower courts' decisions. The court ruled that the Act does not violate the pension protection clause because the ability to vote in local pension board elections and control local pension fund investments are not constitutionally protected benefits. They also ruled that the Act does not violate the takings clause because the plaintiffs do not have a private property right in the funds that are to be transferred to the new statewide funds. The Act only changes how local fund assets are managed and invested without affecting the ultimate use of those assets to pay the benefits of local fund members. Thus, the Act remains in effect. View "Arlington Heights Police Pension Fund v. Pritzker" on Justia Law

In the case under consideration, the Supreme Court of the State of Illinois affirmed the dismissal of Waukegan Hospitality Group, LLC's appeal by the appellate court due to lack of jurisdiction. Waukegan Hospitality Group, LLC filed a notice of appeal five days after the deadline and did not file a motion seeking leave to show good cause or a reasonable excuse for the late filing. Despite the Group's claim that it had electronically submitted the notice of appeal on the due date and that the clerk erroneously rejected it, the Court ruled that the Group failed to seek recourse for its untimely filing as required by the rules of the Illinois Supreme Court. The Court noted that the record did not support the Group's factual assertions and that the Group did not utilize the remedies available to it, making its claim of due process violation baseless. Therefore, the Court held that the appellate court correctly ruled that it lacked jurisdiction to hear the Group's appeal. The case originated from a two-count complaint for eviction filed by the Group against Stretch's Sports Bar & Grill Corporation, in which the trial court ruled in favor of the defendant. View "Waukegan Hospitality Group, LLC v. Stretch's Sports Bar & Grill Corp." on Justia Law

In the case before the Supreme Court of the State of Illinois, the City of Rock Falls filed a petition against Aims Industrial Services, LLC. The petition sought to enforce compliance with a City ordinance requiring the replacement of a private sewage disposal system with a connection to the City’s public sewage disposal system upon the sale or transfer of any property within the City limits. The trial court determined it would be inequitable to grant the City an injunction and denied the City’s petition. The appellate court reversed this decision, holding that the trial court erred in considering the equities when deciding whether to grant the injunction, as the City sought enforcement of an ordinance that specifically authorized injunctive relief.The Supreme Court of the State of Illinois affirmed the judgment of the appellate court, stating that when a statute or ordinance expressly authorizes injunctive relief, the court has no discretion to refuse to grant the injunctive relief once a violation of the statute or ordinance has been established. The Supreme Court clarified that in such cases, balancing of the equities is not necessary since a violation of the statute or ordinance implies a harm to the public. Therefore, the trial court's refusal to grant the injunction based on its own balancing of the equities was an error. View "City of Rock Falls v. Aims Industrial Services, LLC" on Justia Law

In the case before the Supreme Court of the State of Illinois, the State of Illinois, represented by the Attorney General, alleged that Elite Staffing, Inc., Metro Staff, Inc., and Midway Staffing, Inc. (collectively, the staffing agencies) violated the Illinois Antitrust Act. The agencies, which supplied temporary workers to a company called Colony Display, were claimed to have agreed to fix wages for their employees at below-market rates and agreed not to hire each other's employees. The staffing agencies argued that the Act did not apply to the charged conduct, and the case was sent to the Supreme Court for interlocutory review.The Supreme Court held that the Illinois Antitrust Act does not exempt agreements between competitors to hold down wages and to limit employment opportunities for their employees from antitrust scrutiny. For the purposes of the Act, the court clarified that "service" does not exclude all agreements concerning labor services. It particularly noted that multiemployer agreements concerning wages they will pay their employees and whether they will hire each other's employees may violate the Act unless the agreement arises as part of the bargaining process and the affected employees, through their collective bargaining representatives, have sought to bargain with the multiemployer unit.The court vacated the appellate court’s answer to a question it had formulated and remanded the case for further proceedings. View "State ex rel. Raoul v. Elite Staffing, Inc." on Justia Law