Justia Illinois Supreme Court Opinion Summaries

Rock Island police responded to a report of shots fired. Rush and Childs were found in a bullet-ridden car. Rush died of his gunshot wounds. Officers spoke to witnesses who had observed a dark Lincoln Town Car at the scene at the time of the shooting. An off-duty police officer had heard the gunshots and had observed a dark Lincoln Town Car fleeing. The Lincoln and its occupants—Phelps and Reed—were stopped. Both implicated Eubanks as the shooter. Police located Eubanks weeks later. He agreed to be interviewed. Eubanks denied any involvement but admitted to being with Phelps and Reed that day. He later stated that Reed had “set it up.” Under a subsequent plea agreement, the parties agreed to a 35-year sentence. Eubanks gave a detailed videotaped statement confessing to the crimes.The court granted a subsequent motion to vacate the plea. At his stipulated bench trial, Eubanks's statement was admitted into evidence. Eubanks was convicted of first-degree murder and sentenced to 50 years in prison. He filed a post-conviction petition alleging that his trial counsel was ineffective for failing to suppress his statement under Illinois Supreme Court Rule 402(f). The appellate court and Illinois Supreme Court affirmed the denial of the petition. The videotaped statement was not part of the negotiation process and, therefore, inadmissible under Rule 402(f). A plea deal was in place when Eubanks gave his statement. Giving that statement was not a condition precedent of the deal but, rather, was a fulfillment of the deal. View "People v. Eubanks" on Justia Law

Ittersagen brought a medical malpractice action against Advocate Medical and Dr. Thakadiyil, alleging that the defendants negligently failed to diagnose him with sepsis and treat him appropriately. A jury was sworn. More than halfway through the trial, the court received a note from a juror, who reported that he had a business relationship with “the Advocate Health Care System Endowment.” The juror, a partner in a company that handles investments, said he believed the endowment was affiliated with but separate from Advocate Medical. He explained that his connection to Advocate Medical was so attenuated that he forgot to mention it during jury selection. The juror insisted that the outcome of the trial would not affect him financially and that he could remain fair and impartial. The trial court denied Ittersagen’s request to remove the juror for actual bias or implied bias and to replace him with an alternate juror. The jury returned a verdict for the defendants.The appellate court and Illinois Supreme Court affirmed, rejecting an argument that the juror’s business relationship with the endowment created a presumption of bias that cannot be rebutted by claims of impartiality. The court noted the lack of evidence of the affiliation between the endowment and Advocate. The juror did not owe Advocate a fiduciary duty and did not have any other direct relationship with the defendants that would create a presumption of juror bias as a matter of law. View "Ittersagen v. Advocate Health and Hospitals Corp." on Justia Law

The Illinois State Police (ISP) revoked Brown’s Firearm Owners Identification (FOID) card due to Brown's 2001 California conviction of a misdemeanor crime of domestic violence (MCDV). On his application, Brown had answered “no” to the question of whether he had ever been convicted of domestic battery or a substantially similar offense. A domestic violence conviction precludes possession of firearms under federal law, 18 U.S.C. 922(g)(9).The Illinois Supreme Court reinstated an order granting Brown’s petition and ordering ISP to issue Brown a FOID card. Under section 10(c) of the FOID Card Act, a circuit court may grant relief to a petitioner whose FOID card has been revoked if the petitioner has not been convicted of a forcible felony under the laws of any jurisdiction within 20 years of the application or at least 20 years have passed since the end of any period of imprisonment imposed in relation to that conviction; the circumstances regarding a criminal conviction, the applicant’s criminal history, and his reputation are such that the applicant will not be likely to act in a manner dangerous to public safety; granting relief would not be contrary to the public interest; and granting relief would not be contrary to federal law.Brown satisfied the federal law test for the “civil rights restored” exception because he lost his right to possess firearms under California law and those rights were subsequently automatically restored by virtue of California law 10 years after his conviction. View "Brown v. Illinois State Police" on Justia Law

In 2003, the Illinois Supreme Court held that, in committing a respondent under the Sexually Dangerous Persons Act (725 ILCS 205/0.01), the circuit court must make an explicit finding that the respondent is substantially probable to commit sex offenses in the future if not confined. The Act was subsequently amended to include the required element of a substantial probability to reoffend within the statutory definition of a sexually dangerous person.In 1973, Snapp pleaded guilty to three counts of indecent liberties with a child. In 1992, he pleaded guilty to aggravated criminal sexual abuse. In 1997, after Snappwas again charged with aggravated criminal sexual abuse, the state filed a petition and obtained his commitment under the Act. In 2004 and 2007, Snapp filed applications for recovery, seeking release from his civil commitment. Both of those applications were denied. In 2010, Snapp filed another application for recovery. A bench trial was held in 2018, The court denied Snapp’s petition, finding he was “still a sexually dangerous person and in need of confinement.” The appellate court vacated, finding that precedent required an express finding of a substantial probability to reoffend.The Illinois Supreme Court reinstated the trial court decision. The General Assembly eliminated the requirement of a separate explicit finding by the circuit court that the respondent is substantially probable to reoffend if not confined. View "In re Commitment of Snapp" on Justia Law

The defendant was convicted of aggravated domestic battery, home invasion, and possession of a stolen or converted motor vehicle. At trial, the victim (defendant’s former girlfriend) testified to having received threatening Facebook Messenger communications that used a nickname, “Masetti Meech” that defendant had used while they were dating. A message under that name led the victim to her car, days after defendant took it. The messages included personal information only defendant would have known. Police found defendant in possession of the victim’s car keys, near her brother’s workplace.The appellate court affirmed, finding that proof of intent to permanently deprive the victim of her car was not required because defendant was charged with conversion or theft. It was sufficient that the victim testified that defendant broke into her residence, committed assault, stole her keys, and took her car. Because the trial court failed to hold a “Krankel" hearing on defendant’s ineffective assistance of trial counsel claim, the State agreed a hearing was necessary, and the appellate court remanded the cause for a preliminary Krankel hearing. The Illinois Supreme Court affirmed, rejecting arguments that the trial court erred by admitting evidence regarding the contents of Facebook messages allegedly sent by defendant and that the state failed to prove defendant guilty beyond a reasonable doubt of possession of a stolen or converted motor vehicle. The prosecution presented sufficient circumstantial evidence properly authenticating the Facebook Messenger messages. View "People v. Brand" on Justia Law

House was convicted of two counts of first-degree murder and two counts of aggravated kidnapping based on his participation in 1993 abductions and shooting deaths of two teenagers. House was 19 at the time of the crimes. He claimed that he had no idea of the larger plan when the victims were driven to the deserted location and that the victims were killed after he left. The circuit court sentenced him to a mandatory natural life term for the murder convictions and 60 years for each aggravated kidnapping conviction, to run consecutively.In 2001, House’s sentence for the kidnappings was reduced to consecutive 30-year terms. House filed a post-conviction petition, asserting actual innocence based on a witness’s recantation of her trial testimony; newly discovered evidence of police misconduct; ineffective assistance of counsel; and that his mandatory sentence of natural life violated the Eighth Amendment and the Illinois constitution's proportionate penalties clause. The appellate court vacated House’s sentence, finding that his mandatory natural life sentence violated the Illinois proportionate penalties provision as applied because it precluded consideration of mitigating factors, specifically House’s age, level of culpability, and criminal history.The Illinois Supreme Court directed the appellate court to vacate its judgment and to reconsider the effect of its 2018 Harris opinion. On remand, the appellate court denied an agreed motion seeking remand and again vacated House’s sentence. The Illinois Supreme Court reversed in part. The appellate court erroneously held that House’s sentence violated the proportionate penalties clause without a developed evidentiary record or factual findings on the as-applied constitutional challenge. The court vacated the dismissal of the actual innocence claim. View "People v. House" on Justia Law

In 2015, Yost was charged with multiple counts of first-degree murder in connection with the fatal stabbing of his former girlfriend, Randall. After Yost was convicted, he notified the court that he had just learned that his appointed counsel, Rau, had represented Randall in a past case; he requested a new trial. Rau also filed a motion for a new trial but did not reference Yost’s allegations of a conflict of interest. The court denied the motion and sentenced Yost to 75 years’ imprisonment. After conducting a preliminary inquiry on remand, the trial court concluded that the allegations had merit and appointed new counsel, Lookofsky, to investigate. Yost’s amended motion for a new trial alleged that Rau had represented Randall, on two prior occasions in an unrelated case. Yost waived any conflict of interest based on Lookofsky’s prior hiring of Rau on an unrelated civil matter and any conflict-of-interest claims based on the judge’s prior representation of Yost’s family members.The court concluded that there was no per se conflict of interest, which would have required automatic reversal of the conviction, absent a waiver. The Illinois Supreme Court agreed. Illinois now recognizes three per se conflicts of interest: when defense counsel has a contemporaneous association with the victim, the prosecution, or an entity assisting the prosecution; when defense counsel contemporaneously represents a prosecution witness; and when defense counsel was a former prosecutor who was personally involved in the defendant's prosecution. Yost did not claim an actual conflict of interest. View "People v. Yost" on Justia Law

School districts sought a judgment declaring that the Governor and the State of Illinois, have a constitutional obligation to provide them with the funding necessary to meet or achieve the learning standards established by the Illinois State Board of Education. Plaintiffs asked the court to enter judgment for the necessary amounts and for the court to “[r]etain jurisdiction to enforce such schedule of payments.”The appellate court and Illinois Supreme Court affirmed the dismissal of the suit. The plaintiffs abandoned their claims against the State; the Governor is not a proper defendant because he does not have authority to grant the relief requested by the plaintiffs. The plaintiffs acknowledged that an appropriation of public funds may come only from the General Assembly. This case does not involve an actual controversy between the parties as required to grant declaratory relief. View "Cahokia Unit School District No. 187 v. Pritzker" on Justia Law

In 2017, an arbitrator found that Western Illinois University violated its collective bargaining agreement with respect to layoffs. In 2018, the arbitrator entered a supplemental award, finding that the University failed to comply with the earlier award. The Illinois Educational Labor Relations Board then found that the University committed an unfair labor practice in violation of the Illinois Educational Labor Relations Act, 115 ILCS 5/14(a)(1), (8), by failing to comply with the two arbitration awards. The Act requires that public education employers arbitrate disputes arising under a collective bargaining agreement. Refusal to comply with the provisions of a binding arbitration award is an “unfair labor practice” under the Act. The appellate court vacated the Board’s decision.The Illinois Supreme Court agreed. An arbitrator in the public educational labor relations context exceeds his authority by reviewing a party’s compliance with his own award in contravention of the Act, which vests exclusive primary jurisdiction over arbitration awards with the Board. The Board may not limit the evidence it will consider in an unfair labor practice proceeding under the Act to the evidence before the arbitrator. Under the Act, arbitrators retain limited jurisdiction of the awards for the sole purpose of resolving remedial issues that may arise from the award itself. View "Western Illinois University v. Illinois Educational Labor Relations Board" on Justia Law

On November 25, 2015, a police officer, investigating an accident, found Rogers in physical control of the vehicle and suspected him to be under the influence. The officer charged Rogers under 625 ILCS 5/11-501(a)(4). At a hospital, Rogers underwent a blood test, which revealed the presence of THC. The officer filed the uniform citation on December 1, 2015. On December 14, Rogers’s counsel filed a speedy trial demand. On April 6, 2016, Rogers was charged by superseding information with two counts of misdemeanor DUI. The parties continued the trial to May 20. The circuit court granted the state two continuances after Rogers initially objected but then agreed to the continuance. On September 20, the court granted the state a continuance over Rogers’s objection. On October 28, 2016, the state filed a superseding three-count information. On December 1, the trial was continued by agreement. The trial occurred on January 17, 2018. Rogers, convicted on one count, was sentenced to 12 months of court supervision.The appellate court reversed, reasoning that, because of the similarity of the offenses and the officer having sufficient knowledge to ticket both offenses at the time of the first citation, compulsory joinder applied and the clock for speedy-trial purposes began to run on December 14, 2015. The Illinois Supreme Court reversed. Counsel’s performance could not have been deficient for failing to make an objection where binding precedent would have made such an objection meritless; any motion to dismiss on speedy-trial grounds premised on the compulsory-joinder rule would have been otherwise futile. View "People v. Rogers" on Justia Law