Justia Constitutional Law Opinion Summaries

Plaintiffs, a class of individuals, filed mortgage foreclosure complaints in Illinois circuit courts and paid "add-on" filing fees mandated by section 15-1504.1 of the Code of Civil Procedure. They challenged the constitutionality of these fees, asserting that the statute violated the free access clause of the Illinois Constitution. The Illinois Supreme Court previously agreed, declaring the statute unconstitutional and affirming an injunction against its enforcement.The Will County circuit court initially certified the class and granted partial summary judgment, finding the statute unconstitutional. The appellate court reversed, and the case was remanded. On remand, plaintiffs pursued a refund of the fees. The circuit court dismissed the refund claim, citing sovereign immunity, which bars claims against the State. The appellate court reversed, holding that the circuit court had jurisdiction under the officer-suit exception to sovereign immunity, which allows suits against state officials for unconstitutional actions.The Illinois Supreme Court reviewed the case and held that while the officer-suit exception allowed the circuit court to enjoin the enforcement of the unconstitutional statute, it did not apply to the refund claim. The court determined that the refund claim was a retrospective monetary award to redress a past wrong, which falls under the jurisdiction of the Court of Claims, not the circuit court. Consequently, the Illinois Supreme Court reversed the appellate court's judgment and affirmed the circuit court's dismissal of the refund claim. View "Walker v. Chasteen" on Justia Law

In 1999, Sedrick White, then 20 years old, entered a blind guilty plea to one count of first-degree murder and was sentenced to 40 years in prison by the Cook County circuit court. Over 20 years later, White filed a pro se petition for postjudgment relief under section 2-1401(f) of the Code of Civil Procedure, arguing that his 40-year sentence constituted a de facto life sentence in violation of the Eighth Amendment of the U.S. Constitution and the proportionate penalties clause of the Illinois Constitution. The circuit court denied the petition, stating that the sentence did not violate the Eighth Amendment or the proportionate penalties clause.White appealed the circuit court's decision, arguing that his 40-year sentence violated the proportionate penalties clause. The appellate court affirmed the circuit court's decision, holding that White's guilty plea waived any potential constitutional claim regarding his sentence. The appellate court also found that the circuit court did not err in failing to recharacterize White's section 2-1401 petition as a petition under the Post-Conviction Hearing Act.The Supreme Court of Illinois reviewed the case and agreed with the parties that White's blind guilty plea did not waive his constitutional challenge to his sentence. The court clarified that a defendant who enters a blind guilty plea, with no agreement as to the sentence, does not waive the right to challenge the sentence. However, the court found that White's 40-year sentence was not a de facto life sentence and was not "wholly disproportionate to the offense as to shock the moral sense of the community." The court concluded that White failed to state a meritorious claim that his sentence violated the proportionate penalties clause and affirmed the judgments of the appellate court and the circuit court. View "People v. White" on Justia Law

Defendant Torolan Williams was convicted of first-degree murder for the deaths of five victims and sentenced to a mandatory term of natural life imprisonment. He filed a pro se postconviction petition claiming that his sentence violated the proportionate penalties clause of the Illinois Constitution, arguing that evolving brain science supports treating emerging adults as juveniles for sentencing purposes. Williams was 22 years old at the time of the offenses. He also claimed ineffective assistance of trial and appellate counsel for not raising this issue. The Cook County circuit court summarily dismissed the petition, and the appellate court affirmed the dismissal.The appellate majority held that the petition was frivolous and without merit because Williams did not allege any specific facts about his case, other than his age, to support his claim that the sentencing statute was unconstitutional as applied to him. The dissenting justice believed that Williams had met the low threshold for advancing to the second stage of postconviction review, arguing that a pro se petitioner should not be expected to provide more detailed allegations without the assistance of counsel.The Supreme Court of Illinois reviewed the case and affirmed the lower courts' decisions. The court held that Williams failed to provide sufficient factual detail specific to his circumstances to support his claim that the mandatory life sentence violated the proportionate penalties clause. The court emphasized that a postconviction petitioner must allege more than just their age and general brain science; they must provide specific facts about their background and the circumstances of their case. As a result, the court concluded that Williams' attorneys were not ineffective for failing to raise the meritless issue at sentencing or on direct appeal. View "People v. Williams" on Justia Law

Joseph Rothe was convicted of armed robbery with a dangerous weapon other than a firearm and sentenced to life imprisonment. He filed a pro se petition for relief from judgment, arguing that his conviction violated the proportionate penalties clause of the Illinois Constitution because the elements of armed robbery with a weapon other than a firearm and armed violence with a Category III weapon are identical, but the penalties are different. The Madison County circuit court dismissed his petition as untimely.The appellate court affirmed the dismissal but on different grounds. It held that the petition was timely because constitutional challenges can be raised at any time. However, it rejected Rothe’s claim on the merits, ruling that the offenses do not have identical elements because they define "dangerous weapon" differently. The appellate court concluded that the armed robbery statute's broad definition of dangerous weapons is distinct from the specific list of Category III weapons in the armed violence statute.The Supreme Court of Illinois reviewed the case and affirmed the appellate court's judgment. The court held that the definition of "dangerous weapon" under the armed robbery statute is broader than the defined list of Category III weapons in the armed violence statute. Therefore, the two statutes do not contain identical elements, and Rothe's claim that his conviction violated the proportionate penalties clause was without merit. The court concluded that the armed robbery and armed violence statutes are not identical offenses, and there was no violation of the proportionate penalties clause. The dismissal of Rothe’s petition was affirmed. View "People v. Rothe" on Justia Law

In this case, the defendant was convicted of first-degree murder, aggravated discharge of a firearm, conspiracy to commit aggravated discharge of a firearm, and two counts of perjury following a bench trial in the Circuit Court of Jackson County. The charges stemmed from a shooting incident in which the defendant was injured and subsequently treated in a hospital trauma room. The defendant filed a motion to suppress evidence, arguing that the police violated his Fourth Amendment rights by seizing his clothing from the trauma room without a warrant. The trial court denied the motion, finding that the clothing was in plain view and that the defendant had consented to the seizure.The Appellate Court, Fifth District, affirmed the trial court's decision to deny the motion to suppress but vacated the defendant's conspiracy and one perjury conviction. The appellate court addressed the defendant's new argument that he had a reasonable expectation of privacy in the trauma room, ultimately finding that he had forfeited this issue by raising it for the first time in his motion for a new trial. However, the court chose to address the issue and concluded that the defendant did not have a reasonable expectation of privacy in the trauma room.The Supreme Court of Illinois reviewed the case and affirmed the appellate court's judgment. The court held that the defendant did not meet his burden of establishing a reasonable expectation of privacy in the trauma room. The court considered factors such as ownership, legitimate presence, possessory interest, prior use, ability to control or exclude others, and subjective expectation of privacy. The court found that the defendant had no ownership or possessory interest in the trauma room, did not introduce evidence of the ability to exclude others, and failed to demonstrate a subjective expectation of privacy. Consequently, the trial court's denial of the motion to suppress was upheld. View "People v. Turner" 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

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

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 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

Sergeant Albee saw a truck pulling a partially loaded car hauler semitrailer with no driver’s side markings indicating the company name or the DOT number required by federal regulations. The hauler was only partially loaded, which Albee found unusual; no registration was displayed on the trailer. During the subsequent traffic stop, Webb displayed “a state of panic” and had no organized documentation. He volunteered that he had been stopped several times and that the vehicle had been checked for drugs. Albee found that statement “bizarre.” Webb gave Albee a cab card that was Illinois apportioned, but the displayed license plate was from California. Albee performed a free air sniff test with his canine partner. After a positive alert on the trailer, a search revealed an unlicensed firearm and 2736 grams of cannabis–street value $40,000.Webb was convicted of cannabis trafficking, possession of cannabis with intent to deliver, and possession of cannabis. The appellate court and Illinois Supreme Court affirmed, rejecting Webb’s argument that his counsel was ineffective for failing to move to suppress the cannabis on the basis that the positive canine alert, without more, was not sufficient to establish probable cause following changes to Illinois cannabis legislation. Albee relied on more than the dog sniff. The totality of the facts and circumstances justified a reasonable person in believing that the vehicle contained contraband or evidence of criminal activity. View "People v. Webb" on Justia Law