Justia Illinois Supreme Court Opinion Summaries

The Supreme Court of Illinois reversed the circuit court's decision granting landowners' motion to dismiss based on section 8-406.1 of the Public Utilities Act, holding that the circuit court lacked the necessary jurisdiction to review the legality and constitutionality of the Commission's administrative proceedings. In this case, the circuit court's sole rationale for granting those motions was its conclusion that the Commission's proceedings were in violation of due process. Because the legality and constitutionality of the Commission's proceeding was beyond the circuit court's power to decide, its answer to that question could not form the basis for dismissing the complaints here. View "Ameren Transmission Co. of Illinois v. Hutchings" on Justia Law

In this strict product liability action, the Supreme Court of Illinois affirmed the appellate court's judgment and remanded to the trial court for its determination of whether the manufacturer of flexible bulk containers, Taihua Group, "is unable to satisfy a judgment as determined by the court," as mandated by section 2-621(b)(4) of the Illinois Code of Civil Procedure.The court rejected the "bankrupt or nonexistent" standard for reinstatement under section 2-621(b)(4) promulgated in Chraca v. U.S. Battery Manufacturing Co., 2014 IL App (1st) 132325, and overruled that decision. Rather, the court read the statute to permit the trial court to rely on a broader range of factors to determine if a particular manufacturer is "unable to satisfy" the judgment against it. View "Cassidy v. China Vitamins, LLC" on Justia Law

The Supreme Court of Illinois affirmed defendant's conviction for unlawful delivery of a controlled substance within 1000 feet of a church in violation of the Illinois Controlled Substances Act. The court held that the evidence was sufficient for a rational trier of fact to find that the evidence presented gave rise to a reasonable inference that the location was a church and that it was functioning as it purported to be at the time of the offense. View "People v. Newton" on Justia Law

Applying People v. Burns, 2016 IL 118973, which held that the warrantless use of a drug-detection dog at a defendant’s apartment door, located within a locked apartment building, violated a defendant’s rights under the Fourth Amendment, the Supreme Court of Illinois affirmed the lower courts' judgment that the police violated defendant's Fourth Amendment rights by conducting a dog sniff of the threshold of defendant's apartment, located on the third floor of an unlocked apartment building. The court also held that the good faith exception to the exclusionary rule did not apply in this case. View "People v. Bonilla" on Justia Law

American Family filed a declaratory judgment action against Walter and Lisa Krop, contending their homeowner's insurance policy did not cover a tort action pending against their son. The Krops filed a counterclaim against American Family and a third-party claim against Andrew Varga, an insurance agent for American Family. The appellate court reversed the circuit court's dismissal of the Krops' claims as untimely.The Supreme Court of Illinois held that when customers have the opportunity to read their insurance policy and can reasonably be expected to understand its terms, the cause of action for negligent failure to procure insurance accrues as soon as the customers receive the policy. In this case, the complaint was filed over two years after the Krops received their policy and the complaint failed to plead facts that would support any recognized exception to the expectation that customers will read the policy and understand its terms. Therefore, their claim was untimely and the court reversed the appellate court's decision. View "American Family Mutual Insurance Co. v. Krop" on Justia Law

Defendant was convicted of first degree murder, attempted first degree murder, and aggravated battery with a firearm. Defendant was 18 years and 3 months at the time of the offenses, and he was sentenced to 76 years in prison. The appellate court vacated defendant's sentences and remanded for resentencing, holding that the aggregate prison term violated the proportionate penalties clause of the Illinois Constitution.The Supreme Court of Illinois held that the evidence was sufficient to prove that defendant was guilty beyond a reasonable doubt; defendant forfeited his as-applied challenge under the proportionate penalties clause because defendant did not raise his as-applied constitutional challenge in the trial court, an evidentiary hearing was not held on his constitutional claim, and the court declined to remand the matter for an evidentiary hearing; and defendant's facial challenge to his aggregate sentence under the Eighth Amendment failed because, for sentencing purposes, the age of 18 marks the present line between juveniles and adults. Accordingly, the court reversed the appellate court's judgment vacating defendant's sentences and remanded for resentencing. The court otherwise affirmed the judgment. View "People v. Harris" on Justia Law

The Supreme Court of Illinois reversed the appellate court's decision to reverse the circuit court's order granting defendant's motion to seal his fourth and fifth motions in limine over the objection of intervenors. As a preliminary matter, the court held that the appellate court had jurisdiction over the appeal.The court held that a First Amendment presumption of access did not attach to defendant's motions and the trial court did not abuse its discretion by denying intervenors access to the motions under a common-law right of access. In this case, a thorough review of the hearing on intervenors' request to unseal the motions revealed that the trial court attempted to strike a careful balance among competing interests and remand on this issue was unnecessary. View "People v. Zimmerman" on Justia Law

The Diamond law firm filed a qui tam action against My Pillow, under the Illinois False Claims Act, 740 ILCS 175/1, asserting that My Pillow had failed to collect and remit taxes due under the Retailers’ Occupation Tax Act (ROT) and the Use Tax Act (UTA), and had knowingly made false statements, kept false records and avoided obligations under the statutes. The cause was brought in the name of the state but the state elected not to proceed, yielding the litigation to Diamond. At trial, Diamond, who had made the purchases at issue, served as lead trial counsel and testified as a witness. While an outside law firm also appeared as counsel of record for Diamond, its involvement was extremely small. Diamond essentially represented itself. The court ruled in favor of My Pillow on Diamond’s ROT claims, but in favor of Diamond on Diamond’s UTA claims; ordered My Pillow to pay $782,667; and recognized that the litigation had resulted in My Pillow paying an additional $106,970 in use taxes. A private party bringing a successful claim under the Act is entitled to receive 25%-30% of the proceeds. The court held that My Pillow should pay $266,891, to Diamond; found that Diamond was entitled to reasonable attorney fees, costs, and expenses, and awarded Diamond $600,960. The Illinois Supreme Court affirmed the damage award but held that Diamond could not recover attorney fees for work performed by the firm’s own lawyers. To the extent that Diamond prosecuted its own claim using its own lawyers, the law firm was proceeding pro se. View "Schad, Diamond and Shedden, P.C. v. My Pillow, Inc." on Justia Law

Young was convicted of first-degree murder based on the 2005 stabbing death of his girlfriend. The Morgan County circuit court sentenced him to serve 40 years in prison, with 215 days of presentence custody credit. Young subsequently filed a successive post-conviction petition, which was dismissed. The appellate court declined to address Young's claim that the circuit court erred in failing to award him the correct amount of presentence custody credit, concluding that such a claim cannot be raised for the first time on appeal from post-conviction proceedings. The Illinois Supreme Court held that the claim for additional presentence custody credit under section 5-4.5-100 was forfeited. Young did not object to the presentence-credit calculation at sentencing, in post-trial motions, or in the motion seeking a reduction of his sentence. The issue was not raised on direct appeal or as the basis for a claim of ineffective assistance of counsel, nor was it presented in a timely filed section 2-1401 petition. Section 5-4.5-100 does not indicate legislative intent that claims for presentence custody credit are not subject to forfeiture. Illinois Supreme Court Rule 615(b) did not permit the appellate court to grant Young's claim despite the fact that it was raised for the first time on appeal from post-conviction proceedings. The court nonetheless exercised its supervisory authority to order the circuit court to address the claim and determine the amount of additional presentence custody credit to which Young is entitled. View "People v. Young" on Justia Law

Taylor's family gathered at her mother’s Wheaton apartment to celebrate Taylor’s release from prison. Taylor’s girlfriend, Walker, joined the party. Taylor later called Defendant to arrange a ride home for Walker. When Defendant arrived, Taylor and Walker went to Defendant’s car. Defendant gave Taylor heroin, crack cocaine, a syringe, and a crack pipe (wrapped in a dirty sock that had blood on it). Taylor returned to the apartment, told her children that she was going to take a shower and went into the bathroom, Walker began calling repeatedly. Based on what Walker told him, Taylor’s son alerted family members, who tried to enter the locked bathroom and called 911. Officers arrived, forced the door open, and performed CPR. Paramedics transported Taylor to the hospital, where she was pronounced dead. A jury convicted Defendant of drug-induced homicide, 720 ILCS 5/9-3.3(a). The appellate and Illinois Supreme Courts affirmed, rejecting arguments that the trial court erred in refusing Defendant’s proposed jury instructions on causation and that she was not proved guilty beyond a reasonable doubt. The court declined to abandon the “contributing cause” standard in favor of a “but for” standard. The instruction should be modified in cases of drug-induced homicide where the defendant delivers multiple controlled substances to the victim but is charged with only one of the deliveries; in this case, the failure to do so was harmless error. View "People v. Nere" on Justia Law