Justia Illinois Supreme Court Opinion Summaries

In this case, the defendant, Clayton T. Marcum, was convicted of two counts of aggravated domestic battery and sentenced to consecutive prison terms of seven years on each count. Marcum appealed, arguing that his right to a speedy trial had been violated, he did not knowingly waive his right to counsel, the State failed to prove him guilty of aggravated domestic battery, and the circuit court violated his right to remain silent when it ordered him to participate in the preparation of his presentence investigation report.The appellate court agreed that the evidence was insufficient to prove Marcum guilty of aggravated domestic battery. As a result, his convictions were reduced to Class 3 aggravated batteries and the case was remanded to the trial court for resentencing. The appellate court rejected Marcum's remaining arguments. The defendant appealed to the Supreme Court of the State of Illinois, only contesting his speedy trial and waiver of counsel claim.The Supreme Court of the State of Illinois affirmed the judgment of the appellate court. The court held that a violation of the statutory right to a speedy trial does not alone constitute plain error. The court also found that the trial court substantially complied with Rule 401(a) in admonishing Marcum, therefore he effectively waived his right to counsel at trial and continuing through sentencing. The case was remanded to the trial court for further proceedings consistent with the appellate court’s order remanding the case to the trial court for resentencing on the reduced convictions for aggravated battery. View "People v. Marcum" on Justia Law

This case concerns a challenge to an Illinois statute that prohibits child sex offenders from living within 500 feet of a day care home. The plaintiff, Martin Kopf, who in 2003 had pleaded guilty to aggravated criminal sexual abuse involving a 15-year-old victim, argued that the statute was unconstitutional. The Supreme Court of Illinois determined that the statute did not violate Kopf's substantive due process and equal protection rights, as it was rationally related to the legitimate state interest of protecting children. The court noted that while the law may create difficulties for sex offenders in finding compliant housing, it does not force them to leave their communities. The court reversed the lower court's decision that found the statute facially unconstitutional and remanded the case for further proceedings on the plaintiff's as-applied challenges. View "Kopf v. Kelly" on Justia Law

In 2011, Shamar Griffin entered a guilty plea in the circuit court of Cook County, Illinois, to one count of first-degree murder in exchange for a 35-year sentence and the dismissal of additional charges. Several years later, Griffin filed a motion to file a successive post-conviction petition, alleging actual innocence and ineffective assistance of counsel. The circuit court denied the motion, finding that Griffin's guilty plea precluded his actual innocence claim. The appellate court reversed, allowing Griffin to file a petition alleging actual innocence despite his guilty plea.The Supreme Court of Illinois held that the same standard applies to all petitioners when determining whether to grant leave to file a successive post-conviction petition based on an actual innocence claim, regardless of whether the petitioner was convicted following a trial or pleaded guilty. The court also held that each claim in a successive post-conviction petition must meet the applicable standard in order to advance to second-stage post-conviction proceedings.In this case, the court found that Griffin presented a colorable claim of actual innocence based on newly discovered evidence that, if true, could lead to his acquittal on retrial. This evidence included two affidavits identifying a different individual as the actual shooter. The court affirmed the appellate court's decision allowing Griffin to file a successive post-conviction petition based on his actual innocence claim, but it remanded the case to the appellate court for further consideration of Griffin's claim of ineffective assistance of counsel. View "People v. Griffin" on Justia Law

This case involves a dispute between a grain producer, Robert Miller, and the Illinois Department of Agriculture over compensation from the Illinois Grain Insurance Fund. The fund is intended to compensate grain producers for losses incurred when a licensed grain dealer or a licensed warehouseman fails. Miller made a claim with the Department after his grain dealer, SGI Agri-Marketing, LLC, failed before making payment under a “price later contract.”A key issue in the case was the interpretation of the Grain Code's provision concerning the pricing of grain under a “price later contract.” According to the Code, if such a contract is not signed by all parties within 30 days of the last date of delivery of grain intended to be sold by the contract, then the grain is automatically priced on the next business day after those 30 days, at the market price of the grain at the close of that day.Miller argued that the grain was priced when he signed a purchase confirmation, which was within the 160-day window before the failure of the dealer, thus entitling him to compensation from the fund. The Department contended that the Grain Code automatically priced the grain as a matter of law on the next business day after 30 days from the last grain delivery, as the parties had not signed a contract agreeing to a pricing formula by then.The Supreme Court of the State of Illinois agreed with the Department’s interpretation. It held that the statute was unambiguous and provided that the grain would be priced as a matter of law on the next business day after 30 days from the last delivery. Therefore, because the grain was priced outside the 160-day protection window prescribed by the Grain Code, Miller was not eligible for compensation from the fund. The Supreme Court affirmed the circuit court’s judgment and reversed the appellate court's judgment. View "Miller v. Department of Agriculture" on Justia Law

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