Justia Illinois Supreme Court Opinion Summaries

In the state of Illinois, a group of active and retired members of local police and firefighter pension funds filed a complaint against the Governor and other officials, challenging the constitutionality of Public Act 101-610. This Act amended the Illinois Pension Code and consolidated all local police and firefighter pension fund assets into two statewide pension investment funds. The plaintiffs claimed the Act violated two provisions of the Illinois Constitution: the pension protection clause and the takings clause. They argued that the Act diminished their pension benefits by diluting their voting power and control over investment decisions, and by imposing costs associated with the Act's implementation, including repayment of any transition loans. The Supreme Court of Illinois disagreed with the plaintiffs, affirming the lower courts' decisions. The court ruled that the Act does not violate the pension protection clause because the ability to vote in local pension board elections and control local pension fund investments are not constitutionally protected benefits. They also ruled that the Act does not violate the takings clause because the plaintiffs do not have a private property right in the funds that are to be transferred to the new statewide funds. The Act only changes how local fund assets are managed and invested without affecting the ultimate use of those assets to pay the benefits of local fund members. Thus, the Act remains in effect. View "Arlington Heights Police Pension Fund v. Pritzker" on Justia Law

In the case under consideration, the Supreme Court of the State of Illinois affirmed the dismissal of Waukegan Hospitality Group, LLC's appeal by the appellate court due to lack of jurisdiction. Waukegan Hospitality Group, LLC filed a notice of appeal five days after the deadline and did not file a motion seeking leave to show good cause or a reasonable excuse for the late filing. Despite the Group's claim that it had electronically submitted the notice of appeal on the due date and that the clerk erroneously rejected it, the Court ruled that the Group failed to seek recourse for its untimely filing as required by the rules of the Illinois Supreme Court. The Court noted that the record did not support the Group's factual assertions and that the Group did not utilize the remedies available to it, making its claim of due process violation baseless. Therefore, the Court held that the appellate court correctly ruled that it lacked jurisdiction to hear the Group's appeal. The case originated from a two-count complaint for eviction filed by the Group against Stretch's Sports Bar & Grill Corporation, in which the trial court ruled in favor of the defendant. View "Waukegan Hospitality Group, LLC v. Stretch's Sports Bar & Grill Corp." on Justia Law

In the case before the Supreme Court of the State of Illinois, the City of Rock Falls filed a petition against Aims Industrial Services, LLC. The petition sought to enforce compliance with a City ordinance requiring the replacement of a private sewage disposal system with a connection to the City’s public sewage disposal system upon the sale or transfer of any property within the City limits. The trial court determined it would be inequitable to grant the City an injunction and denied the City’s petition. The appellate court reversed this decision, holding that the trial court erred in considering the equities when deciding whether to grant the injunction, as the City sought enforcement of an ordinance that specifically authorized injunctive relief.The Supreme Court of the State of Illinois affirmed the judgment of the appellate court, stating that when a statute or ordinance expressly authorizes injunctive relief, the court has no discretion to refuse to grant the injunctive relief once a violation of the statute or ordinance has been established. The Supreme Court clarified that in such cases, balancing of the equities is not necessary since a violation of the statute or ordinance implies a harm to the public. Therefore, the trial court's refusal to grant the injunction based on its own balancing of the equities was an error. View "City of Rock Falls v. Aims Industrial Services, LLC" on Justia Law

In the case before the Supreme Court of the State of Illinois, the State of Illinois, represented by the Attorney General, alleged that Elite Staffing, Inc., Metro Staff, Inc., and Midway Staffing, Inc. (collectively, the staffing agencies) violated the Illinois Antitrust Act. The agencies, which supplied temporary workers to a company called Colony Display, were claimed to have agreed to fix wages for their employees at below-market rates and agreed not to hire each other's employees. The staffing agencies argued that the Act did not apply to the charged conduct, and the case was sent to the Supreme Court for interlocutory review.The Supreme Court held that the Illinois Antitrust Act does not exempt agreements between competitors to hold down wages and to limit employment opportunities for their employees from antitrust scrutiny. For the purposes of the Act, the court clarified that "service" does not exclude all agreements concerning labor services. It particularly noted that multiemployer agreements concerning wages they will pay their employees and whether they will hire each other's employees may violate the Act unless the agreement arises as part of the bargaining process and the affected employees, through their collective bargaining representatives, have sought to bargain with the multiemployer unit.The court vacated the appellate court’s answer to a question it had formulated and remanded the case for further proceedings. View "State ex rel. Raoul v. Elite Staffing, Inc." on Justia Law

In this case, the Illinois Supreme Court reversed the appellate court's decision, affirming the trial court's decision to allow the postconviction counsel to withdraw and to dismiss the postconviction petition. The defendant, Russell A. Frey, was convicted of three counts of predatory criminal sexual assault of a child and sentenced to 50 years in prison. Frey filed a pro se postconviction petition, arguing ineffective assistance of counsel and a proportionate penalties claim. The trial court appointed counsel for Frey, who later moved to withdraw, arguing that Frey had no meritorious claims. The trial court granted the motion to withdraw and dismissed the petition. On appeal, the appellate court vacated and remanded the case, holding that postconviction counsel did not provide reasonable assistance when he failed to address one of Frey's claims. However, the Supreme Court of Illinois held that Frey failed to rebut the presumption of reasonable assistance arising from counsel's Rule 651(c) certificate, and therefore, the motion to withdraw was not deficient. As such, the Supreme Court of Illinois reversed the appellate court's judgment and affirmed the trial court's orders allowing postconviction counsel to withdraw and dismissing Frey's postconviction petition. View "People v. Frey" on Justia Law

During a bench trial, the defendant Santana Grayer was found guilty of attempted vehicular hijacking. On appeal, Grayer argued that the evidence was insufficient to prove his guilt beyond a reasonable doubt because he was voluntarily intoxicated at the time of the incident. The appellate court affirmed the conviction, reasoning that evidence of voluntary intoxication is no longer relevant to the issue of intent, as the legislature had removed voluntary intoxication as an affirmative defense. However, it also noted that even if voluntary intoxication remained relevant, the evidence failed to establish that Grayer’s state of intoxication was so extreme that he was unable to form the requisite intent.On review, the Supreme Court of Illinois also affirmed Grayer’s conviction, but for different reasons. The court clarified that while voluntary intoxication is no longer recognized as an affirmative defense in Illinois, it can still be considered relevant evidence at trials for specific-intent offenses like attempted vehicular hijacking. This is because a defendant's state of voluntary intoxication might affect their mental state, which is a crucial element in specific-intent crimes. However, in this case, the court concluded that the evidence was sufficient to establish that Grayer had the specific intent to commit the offense of attempted vehicular hijacking, despite his state of voluntary intoxication. The court particularly relied on the defendant's behavior during the incident, including his threats to the victim, his refusal to leave the scene, and his actions suggestive of an attempt to take control of the victim's vehicle. View "People v. Grayer" on Justia Law

The defendant, Justin Devine, was convicted in the circuit court of Kane County of nonconsensual dissemination of private sexual images. He appealed to the appellate court arguing that the State failed to prove him guilty beyond a reasonable doubt. The appellate court agreed with Devine and reduced his conviction to disorderly conduct. The State appealed this decision to the Supreme Court of Illinois.The key issues before the Supreme Court of Illinois included whether Devine "disseminated" the images when he sent them to himself and whether the victim was identifiable from the images. The court held that Devine did disseminate the images when he texted them from the victim's phone to his own, rejecting the reasoning of the appellate court that Devine did not make the images "more widely known" because he already had knowledge of them. The court reasoned that the statute prohibits dissemination of images, not knowledge of images, and that Devine's act of sending the images to himself was an act of dissemination.However, the Supreme Court of Illinois agreed with the appellate court that the victim was not identifiable from the images. The images were close-ups of female genitalia and did not contain any distinctive identifiers. The court concluded that the fact the victim was wearing red nail polish on the day she went to the store or that the images were on her phone did not make her identifiable from the images.Thus, the court affirmed the appellate court's judgment in reducing Devine's conviction to disorderly conduct. View "People v. Devine" on Justia Law

In the case of Clark Alave v. The City of Chicago, the plaintiff, Clark Alave, filed a complaint against the City of Chicago after he was injured when his bicycle struck a pothole. The Illinois Supreme Court ruled that the city did not owe the plaintiff a duty of care under section 3-102(a) of the Tort Immunity Act. The court based this decision on the lack of any affirmative physical manifestations, such as signs or pavement markings, that the city intended for the roadway to be used for bicycling. The court also considered the Divvy bicycle rental station located nearby, but found that this station only indicated that the city permitted, not intended, bicycling on the roadway. The court therefore concluded that the plaintiff was not both a permitted and intended user of the roadway, and thus the city owed him no duty of care. The court reversed the judgment of the appellate court and affirmed the dismissal of the plaintiff's complaint. View "Alave v. City of Chicago" on Justia Law

The attorneys represented Doe in a medical malpractice action against a hospital and other medical staff. During that litigation, the evidence established that, after Doe was admitted to the emergency room of the hospital, he attempted suicide by stabbing himself multiple times. The hospital sought a qualified protective order under the Health Insurance Portability and Accountability Act (HIPAA, 42 U.S.C. 1320d) to gain access to Doe’s protected health information and requested a subpoena pursuant to HIPAA. At trial, Doe testified in detail about his suicide attempt, his injuries therefrom, and his diagnosis., Doe was awarded $4.2 million. Subsequently, the attorneys issued a press release related to the medical malpractice trial describing Doe’s suicide attempt, the resulting injuries, and his diagnoses and commented on the medical malpractice case and Doe’s history for an article published in the Chicago Daily Law Bulletin.Doe alleged that the attorneys violated the Mental Health and Developmental Disabilities Confidentiality Act (740 ILCS 110/1). The Illinois Supreme Court reinstated the dismissal of his case. Doe waived his claims of confidentiality under the Act by voluntarily and publicly disclosing his private health information in a public trial; the qualified protective order under HIPAA did not preclude such waiver. The evidence and testimony divulged during Doe’s medical malpractice trial were not records or communications made in the course of mental health services; therefore, the Act does not apply. View "Doe v. Burke Wise Morrissey & Kaveny, LLC" on Justia Law

The Homeowners Association alleged that M/I’s subcontractors caused construction defects in a Hanover Park development by using defective materials, conducting faulty workmanship, and failing to comply with building codes. The Association alleged that it would be required to repair the defects and “damage to other property caused by the [d]efects.” M/I demanded a defense from Acuity as the additional insured on a commercial general liability policy that Acuity issued to one of its subcontractors on which M/I was an additional insured. Acuity sought a declaratory judgment, arguing that the complaint failed to allege any “property damage” caused by an “occurrence” as those terms are defined by the policy and interpreted by Illinois law. The circuit court granted Acuity summary judgment.The Illinois Supreme Court held that the allegations sufficiently fall within the initial grant of coverage requirement that there be “property damage” caused by an “occurrence.” The court remanded for further consideration of whether policy exclusion bar coverage. To hold that all construction defects that result in property damage to the completed project are always excluded would mean that the exclusions in the policy related to business risk become meaningless. The business risk exclusions contemplate that some construction defects that result in property damage are covered and some are not, depending on various factors. View "Acuity v. M/I Homes of Chicago, LLC" on Justia Law