Justia Illinois Supreme Court Opinion Summaries

The case involves Paul Passafiume, as the independent administrator of the estate of Lois Passafiume, who filed a professional negligence complaint against Daniel Jurak, D.O., and others, alleging wrongful death and survival actions due to negligent care leading to Lois's death in 2014. The case proceeded to a jury trial, where the plaintiff sought damages for loss of material services beyond his remarriage in 2015.In the Grundy County circuit court, the defendants filed a motion in limine to limit the testimony of the plaintiff’s expert witness, economist Stan Smith, regarding the loss of material services to the period before the plaintiff’s remarriage. The court denied this motion, allowing evidence of loss of material services beyond the remarriage. The jury awarded the plaintiff $2,121,914.34 in damages, later reduced due to contributory negligence. The defendants' posttrial motion for a new trial or remittitur was denied, leading to an appeal.The Appellate Court, Third District, affirmed the trial court's decision, holding that a plaintiff’s remarriage does not limit damages for loss of material services in a wrongful death action. The defendants then appealed to the Supreme Court of Illinois.The Supreme Court of Illinois affirmed the appellate court's judgment, holding that in a wrongful death claim under the Wrongful Death Act, a plaintiff’s remarriage does not affect the recoverable damages for the loss of a decedent’s material services. The court overruled previous appellate decisions that had incorporated material services into loss of consortium claims, which terminate upon remarriage. The court maintained that material services remain a separate element of pecuniary damages under the Act, unaffected by remarriage. View "Passafiume v. Jurak" on Justia Law

Aaron and Charles Davis were charged with felony reckless discharge of a firearm in July 2016, leading to the revocation of their Firearm Owners Identification (FOID) cards by the Illinois State Police under section 8(n) of the FOID Card Act. They later pleaded guilty to reduced misdemeanor charges and had their FOID cards reissued in 2017. Subsequently, they filed a lawsuit seeking a declaration that section 8(n) is unconstitutional as applied to individuals charged but not convicted of a felony, and an injunction to prevent future suspensions of FOID cards under similar circumstances.The Circuit Court of Madison County granted the plaintiffs' motion for summary judgment, declaring section 8(n) unconstitutional as applied to individuals charged but not convicted of a felony, and issued a permanent injunction against the suspension of FOID cards under this section. The court found the case moot but applied the public interest exception to mootness, concluding that the plaintiffs had standing. The defendant's motion to stay the order was denied, and the plaintiffs were awarded attorney fees and costs.The Supreme Court of Illinois reviewed the case and found that the plaintiffs lacked standing when they filed the action because their FOID cards had already been restored. The court held that the plaintiffs' claims were moot and that the public interest exception to mootness did not apply to standing. Consequently, the court vacated the circuit court's judgment and remanded the case with directions to dismiss the plaintiffs' first amended complaint. The order granting attorney fees and costs to the plaintiffs was also vacated. View "Davis v. Yenchko" on Justia Law

Plaintiffs, two law firms, provided legal services to defendants regarding the estate of Daniel P. O’Brien Sr. and Mary D. O’Brien. The attorney-client agreement stipulated a contingency fee structure, but defendants terminated the agreement without cause after 19 months. Plaintiffs sought compensation for their services based on quantum meruit, claiming their efforts significantly contributed to a favorable settlement for defendants.The Cook County Circuit Court found that plaintiffs had proven the elements of a quantum meruit claim, including the benefit conferred upon defendants. The court determined the reasonable value of plaintiffs’ services using the contingency fee structure from the attorney-client agreement, awarding plaintiffs $1,692,390.60 after deducting fees paid to subsequent attorneys.The Appellate Court affirmed the entitlement to quantum meruit recovery but reversed the amount awarded, ruling that the attorney-client agreement was void due to a violation of Rule 1.5(e) of the Illinois Rules of Professional Conduct, which requires a written fee-splitting agreement and client consent. The appellate court remanded the case for a new determination of the reasonable value of services.The Illinois Supreme Court reviewed the case and agreed that plaintiffs were entitled to quantum meruit recovery. However, it found that the appellate court erred in reversing the circuit court’s judgment on the reasonable value of services. The Supreme Court held that the attorney-client agreement was not void ab initio and that the circuit court did not commit reversible error in using the contingency fee structure as evidence of value. Consequently, the Supreme Court affirmed the circuit court’s judgment, awarding plaintiffs $1,692,390.60. View "Andrew W. Levenfeld & Associates, Ltd. v. O'Brien" on Justia Law

Ryan Redmond was stopped by Illinois State Police Officer Hayden Combs for speeding and having an improperly secured license plate. Upon approaching the vehicle, Combs detected a strong odor of burnt cannabis. A subsequent search of the vehicle revealed one gram of cannabis in the center console. Redmond was charged with unlawful possession of cannabis and unlawful possession of cannabis by a driver.Redmond filed a motion to suppress the evidence, arguing that the odor of burnt cannabis alone did not provide probable cause for a warrantless search. The Henry County Circuit Court granted the motion, noting the absence of signs of impairment, paraphernalia, or loose cannabis. The court found that the odor of burnt cannabis, standing alone, was insufficient to justify the search. The Appellate Court affirmed, emphasizing the lack of additional evidence supporting the search and dismissing the relevance of the vehicle's travel route and Redmond's living arrangements.The Illinois Supreme Court reviewed the case to determine whether the odor of burnt cannabis alone provides probable cause for a warrantless vehicle search. The court held that, given the legalization and regulation of cannabis in Illinois, the odor of burnt cannabis alone is insufficient to establish probable cause. The court emphasized that the totality of the circumstances must be considered, and in this case, the additional factors cited by the State did not provide sufficient probable cause. Consequently, the court affirmed the lower courts' decisions to suppress the evidence obtained from the search. View "People v. Redmond" on Justia Law

In 1994, Johnny Flournoy was convicted of first-degree murder and armed robbery for the 1991 killing of Samuel Harlib during a robbery at a used car dealership. After numerous unsuccessful appeals and an initial postconviction petition, Flournoy filed a motion in 2021 for leave to file a successive postconviction petition, alleging newly discovered evidence of actual innocence, due process violations, and ineffective assistance of counsel. He supported his claims with affidavits from Ramano Ricks and Elizabeth Barrier.The Cook County Circuit Court denied Flournoy's motion, finding the affidavits did not constitute newly discovered evidence and would not likely change the trial's outcome. The appellate court affirmed, citing People v. Hobley, which held that a postconviction petitioner cannot raise a freestanding claim of actual innocence based on newly discovered evidence used to supplement a constitutional violation claim. The appellate court also found that Flournoy failed to present a colorable claim of actual innocence and was procedurally barred from arguing that one affidavit supported an independent constitutional violation claim.The Illinois Supreme Court reviewed the case and affirmed the lower courts' decisions. The court held that Flournoy could not establish that the evidence in the affidavits was newly discovered, as it was available before trial. The court also found that Flournoy could not demonstrate cause for his due process claims, as he had raised them in prior proceedings. Additionally, the court determined that Flournoy's ineffective assistance of counsel claim was not new and had been previously litigated. Consequently, the court denied Flournoy's motion for leave to file a successive postconviction petition. View "People v. Flournoy" on Justia Law

Trenton Jefferson was tried for first degree murder in the circuit court of St. Clair County. The jury found him guilty but answered negatively to a special interrogatory asking if the State had proven beyond a reasonable doubt that Jefferson personally discharged a firearm causing the victim’s death. The appellate court reversed Jefferson’s conviction for unrelated reasons and ordered a new trial. Jefferson then argued that the jury’s answer to the special interrogatory, under the doctrine of issue preclusion as embodied in the double jeopardy clause of the federal constitution, barred the State from arguing or presenting evidence in his retrial that he personally discharged a firearm causing the victim’s death. The trial court granted the motion, but the appellate court reversed the judgment, holding that the jury’s answer to the special interrogatory did not bar the State from arguing or presenting evidence that Jefferson discharged the firearm.The Supreme Court of the State of Illinois affirmed the judgment of the appellate court. The court concluded that the jury’s answer to the special interrogatory and general verdict could be understood as an indication that the jury was unable to determine whether Jefferson or another individual shot the victim, but that it had determined, beyond a reasonable doubt, that either one or the other did. Because a rational jury could have grounded its verdict upon an issue other than that which Jefferson sought to foreclose from consideration, Jefferson failed to establish that the doctrine of issue preclusion applied. Therefore, the trial court erred in granting Jefferson’s motion to suppress evidence. The State, on retrial, is not barred from again arguing that either Jefferson or the other individual shot the victim. However, the State is barred from seeking a sentence enhancement on remand, as the State conceded that Jefferson cannot get the enhancement ever again. View "People v. Jefferson" on Justia Law

The case involves a dispute over the interpretation of a multi-vehicle insurance policy. The appellants, Mark and Karen Kuhn, were involved in a fatal accident with a semi-truck insured by the appellee, Owners Insurance Company. The Kuhns sought a declaration that the $1 million liability limits for each of the seven vehicles covered under the policy could be aggregated or "stacked" for a total of $7 million in coverage for the accident, despite an "anti-stacking" provision in the policy.The trial court ruled in favor of the Kuhns, finding the policy ambiguous and thus allowing for the stacking of the liability limits. However, the appellate court reversed this decision, holding that the policy's anti-stacking clause was unambiguous and should be enforced as written.The Supreme Court of the State of Illinois affirmed the appellate court's judgment. The court found that the insurance policy, when read as a whole, unambiguously provided a $1 million per accident liability limit and prohibited stacking the liability limits of each insured vehicle. The court rejected the Kuhns' argument that the policy was ambiguous due to the separate listing of liability limits for each vehicle insured. The court held that the policy's anti-stacking provision, in conjunction with the declarations pages, clearly indicated that the limits could not be aggregated. View "Kuhn v. Owners Insurance Co." on Justia Law

The case involves Antuan Joiner, who was convicted of first-degree murder and two counts of attempted murder following a 2014 bench trial in the circuit court of Cook County. The appellate court affirmed his convictions, remanded for a new sentencing hearing, and affirmed the new sentence imposed on remand. Joiner subsequently filed a petition for postconviction relief under the Post-Conviction Hearing Act, which the circuit court summarily dismissed as frivolous and patently without merit. Joiner appealed, arguing that the petition must be advanced to the second stage both because the circuit court failed to rule on it within 90 days after it was filed and docketed and because the claims had merit. The appellate court affirmed the circuit court’s judgment.The Supreme Court of the State of Illinois affirmed the judgment of the appellate court. The court held that the trial court complied with the Act and dismissed Joiner's petition within 90 days after it was filed and docketed on August 4, 2021. The court also found that Joiner was not arguably prejudiced by counsel’s failure to call certain witnesses. Based on the strength of the victims’ identification of Joiner as the shooter, the court concluded that the proposed testimony by the witnesses would not have arguably changed the outcome of the trial. View "People v. Joiner" on Justia Law

A condominium resident suffered serious injuries due to a gasoline leak from an underground storage tank owned and operated by a gas station located over a mile away. The resident filed a lawsuit against the owners and operators of the gas station, alleging common-law negligence and liability based on the violation of Illinois environmental statutes and regulations governing underground storage tanks. The resident passed away during the course of the litigation, and her daughter was appointed as a special representative to continue the action.The Cook County circuit court dismissed the statutory claims, and the appellate court affirmed the dismissal. The courts held that the statutes at issue did not create private statutory rights of action, express or implied. The plaintiff appealed this decision to the Supreme Court of the State of Illinois.The Supreme Court of the State of Illinois affirmed the lower courts' decisions. The court found that there was no express private right of action under the Leaking Underground Storage Tank Program (LUST Program) provisions of the Illinois Environmental Protection Act. The court also concluded that implying a private right of action was not necessary to provide an adequate remedy for violations of the statute. The court noted that the plaintiff's common-law negligence claim, based on the same acts and omissions that she alleged violated the LUST Program of the Act, was a sufficient remedy. Therefore, it was not necessary to imply a private right of action. View "Rice v. Marathon Petroleum Corp." on Justia Law

The case involves Char M. Shunick, who was convicted of unlawful possession of a controlled substance with intent to deliver and unlawful possession of a controlled substance. After his conviction, Shunick filed a petition for postconviction relief, which was summarily dismissed by the circuit court of Knox County. Shunick then filed a motion to reconsider the dismissal, which was also denied by the circuit court. The appellate court found that Shunick's motion to reconsider was untimely and, as a result, his notice of appeal was also untimely. Consequently, the appellate court concluded that it lacked jurisdiction to address the substantive merits of the appeal.The Supreme Court of the State of Illinois affirmed the judgment of the appellate court. The court found that Shunick's motion to reconsider was not timely filed under the Illinois mailbox rule, rendering his subsequent notice of appeal untimely and preventing appellate court jurisdiction over the substantive merits of his appeal. The court also found that the appellate court did not have jurisdiction to order a remand to allow Shunick to cure the jurisdictional defect by supplying a compliant certificate of service. The court concluded that the appellate court correctly followed precedent and concluded that it lacked jurisdiction to remand the cause to allow Shunick to cure the jurisdictional defect by supplementing the record with a compliant certificate of service. View "People v. Shunick" on Justia Law