Justia Illinois Supreme Court Opinion Summaries

In 2001, Wells and her husband were charged with three counts of first-degree murder (720 ILCS 5/9- 1(a)(1), (2), (3)) and concealment of a homicidal death (9-3.1(a)) for allegedly murdering Weyrick and burying his body in their backyard. Wells entered into a fully negotiated plea agreement and agreed to plead guilty to one count of first-degree murder and testify truthfully at her husband’s trial in exchange for a sentence of 40 years’ imprisonment and the dismissal of the remaining charges.More than 16 years later, she petitioned for a reduced sentence (735 ILCS 5/2-1401(b-5)). The Peoria County circuit court found subsection (b-5) inapplicable because Wells had a negotiated plea deal, found her petition untimely, and dismissed it without holding a hearing. The appellate court held that Wells was not provided with an opportunity to respond to the state’s motion to dismiss and vacated the dismissal order without addressing the merits. The Illinois Supreme Court reinstated the dismissal. Any error in depriving Wells of an opportunity to respond to the dismissal motion was harmless as a matter of law because subsection (b-5) does not apply to a person who is sentenced pursuant to a fully negotiated plea agreement. View "People v. Wells" on Justia Law

In January 2018, Lichter filed a personal injury action against Christopher for injuries she suffered in a car accident in February 2016, not knowing that Christopher had died in June 2017. An estate was never opened for Christopher following his death. In April 2018, Lichter successfully moved (735 ILCS 5/2-1008(b)(2)) to appoint Carroll as the special representative of Christopher’s estate for the purpose of defending the lawsuit. Lichter subsequently filed an amended complaint, naming Carroll as the special representative of Christopher’s estate and the defendant. Counsel for Christopher’s insurer, State Farm, appeared on behalf of the defendant. In March 2020, the defendant moved to dismiss Lichter’s complaint (735 ILCS 5/2-619(a)), arguing that the action was time-barred because Lichter never moved to appoint a personal representative of Christopher’s estate before the statute of limitations expiring, as required by 735 ILCS 13- 209(c).The appellate court reversed the dismissal of the case; the Illinois Supreme Court affirmed. Subsection (b)(2), relating to the appointment of a special representative is not limited to situations where the plaintiff is aware of the defendant’s death. It was enacted to streamline the court process when there is no personal representative in place to defend a lawsuit. A plaintiff who learns of a defendant’s death after the statute of limitations has expired is not required to move to appoint a personal representative through the probate court. View "Lichter v. Porter Carroll" on Justia Law

Lighthart had dated both Buchanan and the victim, who was known to have access to large amounts of money. Lighthart drove the victim to a residence, knowing that Buchanan was there intending to rob the victim. Buchanan beat the victim, demanding money, and eventually shot him to death. Lighthart then injected the victim with a solution that contained Drano or attempted to do so. After cleaning the scene, they disposed of the body by setting it on fire inside the victim’s Jeep in a rural field. In 2004, Lighthart, then 23, entered a partially negotiated plea of guilty to first-degree murder, in exchange for the dismissal of other charges and a sentencing cap of 35 years. Lighthart filed a motion to reduce her 35-year sentence and, subsequently, an untimely pro se motion to withdraw her plea, asserting that she was the victim of domestic violence and ineffective assistance of counsel. After an 11-½ year delay following remand and changes in counsel, the appellate court affirmed the dismissal of her 725 ILCS 5/122-1 post-conviction petition as untimely.The Illinois Supreme Court reversed. An ineffective notice of appeal from a negotiated guilty plea, which is dismissed for lack of appellate jurisdiction due to failure to follow procedural requirements (Illinois Supreme Court Rule 604(d)) triggers a six-month limitations period for bringing a postconviction petition. However, under the circumstances, Lighthart could not have been culpably negligent in the untimely filing of her petition. View "People v. Lighthart" on Justia Law

June agreed to watch her sister Jwonda’s children so that Jwonda could visit her friend, Natasha Johnson. Jwonda’s boyfriend, Lane, drove her and her children to June’s apartment, but they argued. Jwonda did not meet Johnson as planned. When Johnson called Jwonda, she heard Lane yelling at her. Johnson went to June’s apartment and left about an hour later. She notified the police about the domestic disturbance. Officers went to June’s apartment. Jwonda and Lane started to leave by the back door. A gun in Lane’s hand discharged, killing Jwonda. Jwonda was pregnant. Her fetus died with her.Lane testified that the gun discharged accidentally. June and Johnson testified that Lane had the gun in his hand as he yelled at Jwonda that she must not leave with Johnson and that Lane threatened to kill Jwonda. The court found Lane guilty of first-degree murder and intentional homicide of an unborn child and held that 720 ILCS 5-8-1(a)(1)(c)(ii) mandated a sentence of natural life in prison because Lane had murdered more than one victim. The appellate court affirmed.The Illinois Supreme Court vacated the sentence. Section 5-8-1(a)(1)(c)(ii) does not apply because the trial court found Lane guilty of only one murder. The sentencing provisions do not change the classification of the offense with which a defendant has been charged and convicted. Intentional homicide of an unborn child is not murder. It is a separate offense with a separate definition. View "People v. Lane" on Justia Law

In 2012, Givens, Dudley, and Strong burglarized a store and attempted to escape by backing a van out of a closed garage door, striking a police officer. Chicago police officers fired their weapons at the van, resulting in Strong’s death and injuries to Dudley and Givens, who were convicted of felony murder, aggravated battery to a peace officer, and possession of a stolen motor vehicle.Dudley, Givens, and Strong’s estate sued the City, alleging the use of excessive force. With respect to Dudley and Givens, the circuit court granted Chicago summary judgment based on the collateral estoppel effect of their prior criminal proceedings. The estate’s lawsuit resulted in a partial verdict for the estate. The circuit court granted Chicago’s motion for judgment notwithstanding the verdict (JNOV) based on the jury’s answers to special interrogatories. The appellate court reversed, holding that collateral estoppel did not bar Dudley and Givens from litigating their claims and the circuit court erred in vacating the verdict.The Illinois Supreme Court agreed that collateral estoppel did not bar the suit by Dudley and Givens. Chicago did not establish with “clarity and certainty” that the identical question was decided in the earlier proceeding The court reinstated the JNOV. The circuit court properly held that the jury’s special finding related to an ultimate issue of fact upon which the rights of the parties depended and was clearly and absolutely irreconcilable with the verdict returned. View "Givens v. City of Chicago" on Justia Law

Pacheco was convicted of aggravated assault and other offenses after he tried to hit a Joliet police officer with his car. During the incident, the officer shot and injured Pacheco. The appellate court reversed, finding that the trial court violated Pacheco’s right to confrontation by prohibiting defense counsel from cross-examining the officer who shot Pacheco as to whether the officer believed he could lose his job if the shooting was found to be unjustified and finding the trial court erred in granting the prosecution’s motion in limine to bar defense counsel from asking the officer and his partner why they did not write police reports regarding the incident.The Illinois Supreme Court reversed the appellate court and remanded. The limitation imposed on the officer’s cross-examination was necessary to avoid a highly prejudicial outcome to Pacheco–the admission of testimony that a review panel had found the shooting to be justified. Cross-examination was not otherwise limited. Because of department policy, the officers had no choice about writing reports and their failure to do so was irrelevant to any question of bias or credibility. The question would have distracted the jury from the question of determining the guilt or innocence of Pacheco. View "People v. Pacheco" on Justia Law

Chicago police arrested Lozano, who was subsequently charged with burglary and possession of burglary tools. Lozano moved to suppress evidence (a car radio, a wallet, and two screwdrivers) arguing that when the officers stopped, detained, and searched him, they neither possessed a warrant nor saw him committing any crimes and could not reasonably suspect that he had committed or was about to commit any crimes or that he was armed and dangerous. Officer Rodriguez testified that he and his partner were driving in an unmarked car, on patrol, and saw Lozano “running at a fast rate of speed” and holding his front pocket. It was raining and wet outside. Rodriguez made a U-turn and approached Lozano, who fled up the stairs of an apparently abandoned building. Rodriguez pursued Lozano and saw a “big bulge” in Lozano’s pocket. Rodriguez handcuffed Lozano, then touched his hooded sweatshirt and felt a rectangular box. He reached inside Lozano’s front pocket and recovered a wallet, two screwdrivers, and a radio. The wallet and radio had been taken from a parked car.The Illinois Supreme Court reversed the trial and appellate courts and held that the officers lacked reasonable suspicion to stop Lozano. The act of running in the rain while holding the front of his pocket did not provide a reasonable suspicion of criminal activity to justify an investigatory stop consistent with the Fourth Amendment and the Illinois Constitution. View "People v. Lozano" on Justia Law

In 2005, Joliet filed a complaint seeking to acquire, by eminent domain, a low-income apartment complex that was owned and managed by the plaintiffs. Following almost 12 years of litigation, Joliet acquired fee simple title to the property in 2017. During the litigation, the apartment complex remained in operation; the plaintiffs paid the property taxes without filing any protest. In 2018, the plaintiffs filed a tax objection complaint, seeking the refund of over $6 million in property taxes paid between the date Joliet filed its condemnation complaint and the date it acquired the property. The plaintiffs maintained that “once title to property acquired by condemnation vests with the condemning authority, it vests retroactively to the date of filing the condemnation petition,” so the landowner is entitled to a refund for any taxes paid after the date of filing. The trial court dismissed the complaint. The appellate court held that the plaintiffs were entitled to a refund.The Illinois Supreme Court reversed, overruling the precedent on which the appellate court relied. The legal premises on which that case rested—that a taking occurs at the time a condemnation action is filed and that the valuation of the property is fixed at that point—no longer exists. The court rejected an argument that the act of filing a condemnation complaint burdened the property and it would be unfair to require the plaintiffs to pay the property taxes that accrued during the condemnation proceeding. View "MB Financial Bank, N.A. v. Brophy" on Justia Law

Jansen was a resident at a skilled nursing facility. Kotalik, with Jansen’s power of attorney for healthcare, signed a “Contract Between Resident and Facility” that provides all civil claims shall be resolved exclusively through mandatory mediation, and, if such mediation does not resolve the dispute, through binding arbitration. The contract waived claims for punitive damages and included a “termination upon death” provision. Jansen suffered several falls, resulting in injuries that contributed to or caused Jansen’s death. Her estate sued, arguing that the defendants had waived their right to mediate and/or arbitrate by participating in litigation for nearly a year, that the arbitration clause was procedurally and substantively unconscionable, and that Kotalik, as Jansen’s POA for healthcare, lacked the authority to execute an arbitration clause on Jansen’s behalf.The Illinois Supreme Court affirmed the denial of the motion. By the express terms of the contract, once the resident died, the contract ceased to exist, including the forum provision. The court did not address the other arguments. View "Clanton v. Oakbrook Healthcare Centre, Ltd." on Justia Law

The Protect Illinois Communities Act restricts firearms and related items that the Act defines as “an assault weapon, assault weapon attachment, .50 caliber rifle, or .50 caliber cartridge” (assault weapons), 720 ILCS 5/24-1.9(b), and “large capacity ammunition feeding device[s],” section 24-1.10(b)). Certain restrictions do not apply to law enforcement agencies and individuals who complete firearms training as part of their employment in law enforcement, corrections, the military, and private security (trained professionals), and individuals who possessed assault weapons or LCMs (large capacity magazines) before the restrictions became effective.The circuit court of Macon County entered declaratory judgment, finding that the restrictions facially violated the Illinois Constitution because the exemptions deny the “law-abiding public” equal protection and constitute special legislation. On appeal, opponents of the law alleged for the first time that, regardless of the exemptions, the restrictions violate the second amendment to the U.S. Constitution and violated the three-reading requirement of the Illinois Constitution.The Illinois Supreme Court reversed. The exemptions neither deny equal protection nor constitute special legislation because plaintiffs have not sufficiently alleged that they are similarly situated to and treated differently from the exempt classes. The plaintiffs expressly waived in the circuit court any independent claim that the restrictions impermissibly infringe the Second Amendment and are jurisdictionally barred from renewing their three-readings claim. View "Caulkins v. Pritzker" on Justia Law