Justia Illinois Supreme Court Opinion Summaries

Palmer’s conviction for first-degree murder based on a 1998 Decatur killing was vacated in 2016, based on DNA evidence. He sought a certificate of innocence under 735 ILCS 5/2-702. The state argued that the new forensic evidence did not establish Palmer’s innocence by a preponderance of the evidence: the new evidence established he was not the primary assailant who killed the victim but did “nothing to refute the argument that petitioner may be guilty of the victim’s murder as an accessory or as a participant in a felony murder.” The circuit court rejected Palmer’s contention that the state was limited to arguing that he was guilty of first-degree murder as charged at trial. The appellate court affirmed, holding that Palmer had to prove by a preponderance of the evidence that he was neither the principal nor an accomplice to the charged offense because “[t]he principal and the accomplice are, in the eyes of the law, one and the same,” rejecting Due Process and judicial estoppel arguments.The Illinois Supreme Court reversed. A petitioner seeking a certificate of innocence needs to prove that he was innocent of the offense only as it was originally charged, not that he was innocent of every conceivable theory of criminal liability for that offense. View "People v. Palmer" on Justia Law

In 2007, Johnson agreed to plead guilty to unlawful restraint. The court informed him that unlawful restraint is a Class 4 felony, punishable by one to three years’ imprisonment, and stated that he would be subject to mandatory supervised release. Johnson entered his plea. The factual basis for the plea indicated that Johnson and another threatened the victim with a gun, detained him, and rummaged through his pockets but did not specify the victim’s age. The court did not inform Johnson that a conviction of unlawful restraint committed against a victim under the age of 18 would trigger a requirement to register under the Child Murderer and Violent Offender Against Youth Registration Act, 730 ILCS 154/1. The court accepted the plea and imposed a two-year sentence. In 2016, Johnson sought leave to file a late post-conviction petition. He had discharged his sentence for unlawful restraint but was in prison for failing to register under the Act.The appellate court and Illinois Supreme Court affirmed the summary dismissal of the petition as patently without merit. Johnson lacked standing to seek postconviction relief from the unlawful restraint conviction because he was no longer “imprisoned in the penitentiary” for that offense. Under the Post-Conviction Hearing Act, if a petitioner clearly lacks standing, the petition is necessarily patently without merit. Where there is no dispute that a petitioner’s liberty is not actually restrained due to the conviction, no further inquiry into his standing is necessary. The obligation to register under the Violent Offender Act was a collateral consequence of the unlawful restraint conviction and did not confer standing to challenge that conviction. View "People v. Johnson" on Justia Law

During a routine traffic stop, officers ran a name check on Bass, a passenger, which returned an investigative alert issued by the Chicago Police Department for an alleged sexual assault. Bass was arrested and made incriminating statements to investigators. The court denied a motion to suppress those statements and found him guilty of criminal sexual assault. The appellate court reversed, holding that the traffic stop violated the Fourth Amendment because it was unlawfully prolonged, that Illinois Constitution article I, section 6, provides greater protections than the Fourth Amendment, and that arrests based on investigative alerts, even those supported by probable cause, violate the Illinois Constitution.The Illinois Supreme Court affirmed the reversal of Bass’s conviction, relying solely on the Fourth Amendment, without addressing investigatory alerts or the state constitution. The state failed to meet its burden of showing that the stop was not unlawfully prolonged. Officers cannot lawfully pursue unrelated investigations after quickly completing the mission by claiming that the overall duration of the stop (here, about eight minutes) remained reasonable, nor by waiting to resolve the mission (by writing a ticket or giving a verbal warning) until unrelated inquiries are completed. The name check was unrelated to resolving the red light violation; the officers resolved the traffic violation and then waited to issue the verbal warning so that they could engage in on-scene investigations into other crimes by checking names until they found something worth investigating. View "People v. Bass" on Justia Law

An officer stopped a van, driven by Wise, for speeding. There was a passenger in the front seat and another in the “very back” seat. As the officer spoke with Wise, he detected the odor of burnt cannabis and called for backup. Two officers conducted a probable cause search of the vehicle; one found a firearm and ammunition “in the rear passenger compartment [in] kind of like [a] little cupholder armrest, inside a glove.” The gun was not in plain view. Searching Wise’s handbag, the officer found a large number of prescription pills. Wise, who had a 1995 Iowa conviction for first-degree burglary, was charged with unlawful possession of a firearm by a felon, 720 ILCS 5/24-1.1(a) and unlawful possession of a substance containing oxycodone, 720 ILCS 570/402(c). An officer testified that Wise had told the officer that his brother owned the van, that he knew the gun was present, and that the gun belonged to a friend who also borrowed the van from Wise’s brother. Both passengers stated that the gun did not belong to Wise. The officer estimated that the gun was five to 10 feet away from Wise while he was driving.The Illinois Supreme Court vacated Wise's conviction. The state failed to prove beyond a reasonable doubt that Wise exercised immediate and exclusive control over the area where the firearm was found; his conviction for unlawful possession of a weapon under section 24-1.1(a) on a theory of constructive possession cannot stand. View "People v. Wise" on Justia Law

Northwestern University’s Medill School of Journalism’s “Innocence Project” sought to exonerate Porter for two 1982 murders. Ciolino, a private investigator working with the Project, obtained a videotaped confession from Simon. Porter’s conviction was vacated. Simon pleaded guilty to the murders and was sentenced to 37 years in prison. Porter’s exoneration is regarded as the impetus for the Illinois death penalty moratorium. The tactics Ciolino used to obtain Simon’s confession came under scrutiny. It was alleged that Ciolino promised Simon that he would secure an attorney, Rimland, to represent him. Rimland shared office space with Ciolino and did not challenge Simon’s confession or present other evidence to the court. Ekl began representing Simon and filed a successive post-conviction petition asserting actual innocence. Two witnesses recanted their statements, indicating that those statements were induced by promises made by the Project. The circuit court vacated Simon’s convictions after Simon had served 15 years in prison. In 2015, Crawford published a book, Justice Perverted: How the Innocence Project … Sent an Innocent Man to Prison, which inspired the documentary at issue—Murder in the Park, in which Ekl allegedly made defamatory statements concerning Ciolino. Ciolino’s suit, alleging defamation, false light invasion of privacy, intentional infliction of emotional distress, and civil conspiracy, was dismissed as barred by the one-year statute of limitations. Except as against one defendant, the appellate court reversed. The Illinois Supreme Court affirmed the reinstatement of the claims against Ekl. Because the screenings of the documentary each constituted a separate publication of the allegedly defamatory material, the single-publication rule does not apply. Following the documentary's Chicago screening, Ciolino timely filed his complaint. View "Ciolino v. Simon" on Justia Law

Burge, a certified nursing assistant (CNA) formerly employed as a home health care provider, pled guilty to theft, a Class A misdemeanor after stealing $280 from a client. Days later, Burge moved to withdraw her guilty plea and vacate the judgment, claiming that her plea was not voluntarily entered. The circuit court of Champaign County denied her motion. The appellate court and Illinois Supreme Court affirmed. The trial court did not abuse its discretion in denying Burge’s motion. No manifest injustice occurred because she pled guilty under the misapprehension that she would not automatically lose her employment as a direct result of pleading guilty. Code of Criminal Procedure, 725 ILCS 5/113-4(c), which provides that “[i]f the defendant pleads guilty such plea shall not be accepted until the court shall have fully explained to the defendant” the various collateral consequences of pleading guilty does not apply when a defendant pleads guilty other than at arraignment. The legislature determined that only at arraignment, prior to the appointment of counsel, must a trial court admonish a defendant of the collateral consequences of pleading guilty; here, the defendant pled guilty after arraignment with defense counsel appointed and was properly admonished under Rule 402. View "People v. Burge" on Justia Law

Calumet City held a referendum proposing that candidates could not seek the office of mayor while simultaneously holding an elected, paid state office. Before the outcome of the referendum was certified, Representative Jones of the 29th District of the General Assembly filed nomination papers seeking the office of mayor. The referendum was later certified as adopted. The day after certification, objectors brought suit to bar Jones from appearing on the February 2021 ballot in light of the newly passed referendum. The Municipal Officers Electoral Board for the City of Calumet City sustained the objection and removed Jones from the ballot. The circuit court of Cook County affirmed, directing that Jones’s name appear on the ballot but that all his votes be impounded or suppressed. The appellate court summarily reversed and ordered that Jones appear on the ballot.The Illinois Supreme Court stayed the appellate court order and subsequently reversed in favor of Jones. The referendum became effective on November 24, 2020, the date the election was certified. Because Jones filed his nomination papers on November 16, 2020, he was legally qualified to run for mayor at that time. His nomination papers were not defective at that time. View "Jones v. Municipal Officers Electoral Board for the City of Calumet City" on Justia Law

Birge was convicted of burglary and arson, both Class 2 felonies carrying mandatory class X sentencing based on his criminal history, 730 ILCS 5/5-4.5-95(b). The Livingston County circuit court sentenced Birge to 24 years and 6 months’ imprisonment and to pay the victim $117,230 in restitution.The Illinois Supreme Court affirmed the convictions but vacated Birge’s sentence. In admonishing the jury under Rule 431(b) the trial court properly grouped the principles of presumption of innocence, reasonable doubt, the state’s burden of proof, and the defendant’s right to not testify into one broad statement of law. The prospective jurors expressed their understanding and acceptance of the principles by a show of hands; nothing suggests that the jurors were confused by the court’s presentation and the defense counsel asked follow-up questions. The restitution order, however, lacked a sufficient evidentiary basis for the amount imposed (730 ILCS 5/5- 5-6(f). The trial court must determine the amount of restitution based on such factors as “actual out-of-pocket expenses, losses, [and] damages. View "People v. Birge" on Justia Law

Based on a 2001 gang-related shooting Jackson was convicted in Cook County of first-degree murder and aggravated battery with a firearm. After his direct appeal and an initial post-conviction petition were unsuccessful, he sought leave in the circuit court to file a successive post-conviction petition, arguing that his constitutional right to due process of law was violated at trial by the state’s use of witness statements that were the product of police intimidation or coercion and that he is actually innocent of the crimes for which he was convicted. Jackson attached documents that purport to show a pattern and practice of witness intimidation in other cases by the police detectives who obtained the witness statements, as well as exculpatory affidavits.The appellate court and Illinois Supreme Court affirmed the denial of the petition. The material regarding police misconduct attached to Jackson’s petition is not relevant to establishing a pattern and practice of witness intimidation by the interviewing detectives in this case, so Jackson has not satisfied the “prejudice” prong of the cause-and-prejudice test. Jackson cannot set forth a colorable claim of actual innocence because his supporting affidavits are not new; principles of “fundamental fairness” do not require additional proceedings. View "People v. Jackson" on Justia Law

Rehfield sued the Diocese, alleging retaliatory discharge and violation of the Whistleblower Act (740 ILCS 174/1). Rehfield was an educator for more than 43 years. In 2012, Rehfield was hired as the principal of St. Raphael Catholic School in Naperville. In 2016, Rehfield alerted teachers about an out-of-state parent, MacKinnon, whom Rehfield believed to present a threat based on his emails concerning his daughter. Eventually, the police issued an arrest warrant for MacKinnon. Against the advice of the police and the supervising priest, Rehfield distributed a photograph of MacKinnon and informed her staff to call 911 if they saw MacKinnon. In May 2017, the Naperville Sun published an inaccurate story about the situation: “Man vowed to ‘terrorize’ Naperville school: authorities.” Days after a meeting with angry parents, the Diocese terminated RehfieldThe trial court dismissed, reasoning that Rehfield was employed pursuant to a contract and “[c]ommon law retaliatory discharge claims may only be asserted by employees terminable at will.” The trial court also cited the doctrine of ecclesiastic abstention. The appellate court affirmed, stating that Rehfield was not a secular employee but a “member of the clergy.” The Illinois Supreme Court affirmed. Rehfield’s formal title (lay principal) does not necessarily indicate a religious role but her job duties entailed numerous religious functions in furtherance of the school’s Catholic mission. There is sufficient evidence to conclude that she was a minister and that the ministerial exception bars her whistleblower claim. View "Rehfield v. Diocese of Joliet" on Justia Law