Justia Constitutional Law Opinion Summaries

Articles Posted in Supreme Court of Illinois
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In 2002, Lusby was convicted of first-degree murder, aggravated criminal sexual assault, and home invasion and sentenced to 130 years’ imprisonment. Though he was 23 years old at the time of the trial, he was only 16 years old at the time of the offenses. After an unsuccessful direct appeal and post-conviction proceedings, he sought leave to file a successive post-conviction petition, asserting that his sentencing hearing was constitutionally inadequate under the Supreme Court’s 2012 decision, Miller v. Alabama. The Will County Circuit Court denied that motion. The appellate court reversed.The Illinois Supreme Court reinstated the trial court’s decision, denying relief. Lusby failed to show cause and prejudice such that the trial court should have granted leave to file a successive post-conviction petition. Lusby had every opportunity to present mitigating evidence but chose not to offer any. The trial court considered his youth and its attendant characteristics before concluding that his future should be spent in prison. The de facto discretionary life sentence passes constitutional muster under Miller; Lusby has not shown prejudice under 725 ILCS 5/122-1(a)(1). Miller does not require a court to use “magic words” before sentencing a juvenile defendant to life imprisonment but only requires consideration of “youth-related factors.” View "People v. Lusby" on Justia Law

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After a dispute at his parents’ house, Gaines was charged with criminal damage to property, criminal trespass to a residence, misdemeanor criminal damage to property, misdemeanor domestic battery, and misdemeanor aggravated assault. At a hearing, the judge initially accepted a negotiated plea to two counts, but subsequently rejected the plea and reinstated the charges. At trial, Gaines was convicted of felony criminal trespass to a residence and misdemeanor domestic battery. Gaines did not raise a double jeopardy argument in post-trial motions. The appellate court ordered his release.The Illinois Supreme Court reversed, reinstating the misdemeanor battery conviction. In the context of a guilty plea proceeding, jeopardy attaches when the court unconditionally accepts the guilty plea. A formal finding of guilt is not required, nor is imposition of a sentence. The court unconditionally accepted Gaines’s guilty plea; jeopardy attached. Jeopardy did not, however, terminate improperly, where the court sua sponte vacated the guilty plea. The court did not abuse its discretion because it had “good reason to doubt the truth of the plea.” Because jeopardy did not terminate improperly, (720 ILCS 5/3-4(a)), Gaines’s subsequent trial on the same offense did not violate the prohibition against double jeopardy. Gaines cannot demonstrate prejudice, so his claim of ineffective assistance of counsel fails. View "People v. Gaines" on Justia Law

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Hollahan was charged with aggravated DUI. His initial jury trial ended in a mistrial when a video recording of the traffic stop was inadvertently played beyond the point of admissible evidence. During a second jury trial, a redacted video of the traffic stop was played for the jury. Following the presentation of evidence, closing arguments, and instruction as to the applicable law, the jury retired to deliberate. Shortly thereafter, the jury asked to watch the video again. The judge granted that request. The video was shown to the jury in the courtroom because the court did not have the “arrangement” necessary to allow the jury to view the video in the jury deliberation room. The court allowed Hollahan, the attorneys, and two alternate jurors to remain in the courtroom while the jury watched the video. Defense counsel did not object. Before the jury was returned to the courtroom, the court admonished that the jury would be watching the video and that “[n]o one will have any conversation.” The judge told the jurors, “we will not be talking to you other than to get the video, period.” After watching the video, the jury returned to the jury room and found Hollahan guilty.The Illinois Supreme Court found no reversible error. Deliberations were not taking place while the jurors were watching the video in the presence of non-jurors and there was no communication with non-jurors. Even if there were error, Hollahan has not shown that he was prejudiced by the procedure employed by the circuit court. View "People v. Hollahan" on Justia Law

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Named plaintiffs filed a two-count class-action complaint on behalf of “all residents of the City of Chicago who have resided in an area where the City has replaced water mains or meters between January 1, 2008, and the present.” The complaint raises claims of negligence and inverse condemnation in relation to the replacement of water meters and water main pipes, as well as the partial replacement of lead service lines that run between the water mains and residences throughout Chicago. The complaint claimed the city’s actions created an increased risk that lead will be dislodged or leach from the residents’ individual service lines. The appellate court reversed the dismissal of the complaint.The Illinois Supreme Court reinstated the dismissal. The complaint did not allege that anyone is suffering from any physical impairment, dysfunction, or physically disabling consequence caused by the city's actions. An increased risk of harm is not, itself, an injury consistent with the traditional understanding of tort law. The plaintiffs have alleged only that the replacement of water mains and meters has made the proposed class members’ property “more dangerous.” The concept of “dangerousness” is not susceptible to objective measurement and, thus, cannot by itself constitute damage under the Illinois takings clause. View "Berry v. City of Chicago" on Justia Law

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In 1998, a jury convicted Stoecker of first-degree murder and aggravated criminal sexual assault of a 15-year-old girl. His convictions and sentences were affirmed. Stoecker filed numerous unsuccessful petitions for collateral relief. In 2005 Stoecker filed a petition for relief from judgment, arguing that the procedures in imposing his life sentence for murder violated the Supreme Court’s 2000 “Apprendi” holding that, other than the fact of a prior conviction, any fact that increases the penalty beyond the statutory maximum sentence must be submitted to a jury and proved beyond a reasonable doubt. Appointed defense counsel acknowledged that the Illinois Supreme Court had held that Apprendi did not apply retroactively to cases whose direct appeals had been exhausted. The petition was dismissed. Although Stoecker filed subsequent petitions claiming ineffective assistance of counsel, he did not appeal the Apprendi ruling.Seven years later, Stoecker again sought relief from judgment, raising the Apprendi issue. The appellate court affirmed the dismissal of the petition as untimely. Four years later, Stoecker again sought relief from judgment, arguing that under recent Supreme Court decisions, Apprendi applies retroactively to cases on collateral review. The state moved to dismiss the petition. Four days later, the circuit court dismissed the petition. The state was present but made no argument. Appointed counsel was apparently not notified of the proceeding. The court ruled that the state was correct as a matter of law. Stoecker filed an unsuccessful pro se motion to reconsider.The Illinois Supreme Court affirmed. Any violation of Stoecker’s due process rights was harmless because the deficiencies in the petition could not be cured. The petition was untimely, barred by res judicata, and meritless. Any deficient performance by appointed counsel did not warrant remand. View "People v. Stoecker" on Justia Law

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In 2014, a $30,880 judgment covering backpay and pre-judgment interest was entered against Oakridge Nursing & Rehabilitation Center, LLC, for its age and disability discrimination against a former employee, in violation of the Illinois Human Rights Act, 775 ILCS 5/1-101. Oakridge Rehab had already gone out of business and transferred the assets and operation of its nursing home facility to Oakridge Healthcare Center, LLC in 2012. Unable to enforce the judgment against Oakridge Rehab, the state instituted proceedings to enforce the judgment against Oakridge Healthcare.The Illinois Supreme Court ruled in favor of Oakridge Healthcare, declining to adopt the federal successor liability doctrine in cases arising under the Human Rights Act. The court noted four limited exceptions to the general rule of nonliability for corporate successors and declined to apply the fraudulent purpose exception, which exists “where the transaction is for the fraudulent purpose of escaping liability for the seller’s obligations.” The court stated that it is within the legislature’s power to abrogate the common-law rule of successor nonliability or otherwise alter its standards through appropriately targeted legislation for employment discrimination cases. View "Department of Human Rights v. Oakridge Healthcare Center, LLC" on Justia Law

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Deleon was charged with four counts of criminal sexual assault. The conditions of Deleon’s bond release prohibited him from contacting the victim or visiting her home, school, or workplace. Under 725 ILCS 5/112A-11.5, the State’s Attorney sought a plenary civil no-contact order prohibiting Deleon from contacting the victim, harassing or stalking her, and entering her place of employment. The circuit court orally pronounced that section 112A-11.5 was unconstitutional, both on its face and as applied; an evidentiary hearing was never held nor evidence proffered as to its unconstitutionality as applied to Deleon. The court found that the statute allows the state to make a prima facie case for the issuance of a protective order by producing the indictment without requiring the alleged victim to testify and be subject to cross-examination; that the requirement that a defendant present evidence of a meritorious defense to rebut the prima facie evidence violated constitutional protections against self-incrimination; and that the statute improperly shifts the burden of persuasion to the defense.The Illinois Supreme Court reversed. There is no basis for concluding that due process precludes the use of an indictment, alone, for restricting a defendant’s liberties before trial. The government has a substantial interest in protecting victims of sexual assault and related crimes from continued contact by the accused pending trial. The conditions of the no-contact order were relatively limited and largely identical to the restraints imposed as conditions of pretrial bond release. There is no legal compulsion for a defendant to rebut the prima facie evidence and no self-incrimination concerns. View "People v. Deleon" on Justia Law

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Robinson and two others were charged with the 1997 shooting death of Giles. Tucker testified that Robinson told him that he had killed Giles and had given details about the killing and the disposal of the body and of evidence. Muhammad testified that she had driven the men to the scene where the body was burned. McClendon testified that she was Robinson’s girlfriend and that Robinson told her they had burned Giles’s body and that he had shot Giles in the head. McClendon identified a picture of a rifle and testified that she had seen that weapon twice within the month before the shooting. After being advised of his rights, Robinson, then 18, had confessed to shooting Giles and burning the body. The state did not present physical evidence linking him to the crime; Robinson did not present a defense. His convictions were affirmed. His first post-conviction petition, alleging ineffective assistance of counsel, was unsuccessful.In 2015, Robinson sought leave to file a successive post-conviction petition, 725 ILCS 5/122-1, alleging actual innocence. He asserted that he was not involved in the crimes and that Giles was murdered by Tucker. He attached his own affidavit plus four others. The Illinois Supreme Court reversed and remanded, in favor of Robinson. The only issue is whether Robinson may file his successive post-conviction petition alleging he is actually innocent. The new evidence supporting the petition need not be completely dispositive of innocence but need only be of such a conclusive character as to probably change the result upon retrial. Robinson satisfied the pleading requirements for granting leave to file a successive petition, so his claim must be advanced to second-stage proceedings. The court noted reasons for questioning the credibility of the witnesses at trial and reasons why the affiants might be credible. View "People v. Robinson" on Justia Law

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The Pension Code allowed elected county board members to participate in the Illinois Municipal Retirement Fund (IMRF) if the participant occupied a position requiring 1000 hours of service annually and the public employee filed an election to participate. A 1968 administrative rule required the governing body of a participating employer to adopt a resolution certifying that the position of elected governing body members required the hourly standard. Williamson County complied with the 1968 rule. The plaintiffs satisfied the original requirements for IMRF participation, electing to participate in 2004, 2008, and 2012. In 2016, Public Act 99-900, amended parts of the Pension Code (40 ILCS 5/7-137.2(a), requiring, for the first time, that all county boards certify within 90 days of each general election that their board members were required to work sufficient hours to meet the hourly standard for participation and that members who participate in IMRF submit monthly timesheets. The Fund issued “Special Memorandum #334” to the authorized IMRF agent in every county, explaining the change: “If the County Board fails to adopt the required IMRF participation resolution within 90 days after an election, the entire Board will become ineligible and IMRF participation will end for those Board members.” The Fund also sent a direct mailing to individual county board members participating in IMRF. Williamson County did not timely adopt the required resolution. The Fund notified the plaintiffs that they were not eligible for continued IMRF participation.The Illinois Supreme Court found Public Act 99-900 invalid under Illinois Constitution article XIII, section 5. A public employee’s membership in a pension system is an enforceable contractual relationship; continued IMRF participation was protected from unilateral legislative diminishment or impairment when the plaintiffs became IMRF participants and began accruing the service credits. View "Williamson County Board of Commissioners v. Board of Trustees of the Illinois Municipal Retirement Fund" on Justia Law

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Essure--permanent birth control for women--originally was manufactured and developed by Conceptus, a California corporation. Bayer bought Conceptus. Bayer marketed Essure as safer and more effective than other birth control. Two residents of Madison County, Illinois, filed personal injury complaints, alleging that Essure caused debilitating pain, heavy bleeding that necessitated medication, and autoimmune disorders. including 179 plaintiffs from at least 25 states. Months later, the U.S. Supreme Court issued its “Bristol-Myers” decision. Bayer argued that, following Bristol-Myers, a court cannot exercise specific personal jurisdiction over an out-of-state defendant as to the claims of out-of-state plaintiffs when the conduct giving rise to the claims did not occur in the forum state. The plaintiffs argued Illinois courts had specific personal jurisdiction over Bayer because it “created the Essure Accreditation Program and the marketing strategy for Essure in Illinois,” conducted clinical trials in Illinois, and used Illinois as a testing ground for its physician training program. The appellate court affirmed the denials of motions to dismiss: Bayer “conducted a part of its general business in Illinois, and [p]laintiffs’ claims arose out of" trials conducted, in part, in Illinois.The Illinois Supreme Court reversed. The nonresident plaintiffs identified no jurisdictionally relevant links between their claims and Illinois. The nonresidents have not explained how Illinois could be a convenient location for this litigation; they were not implanted with their devices here and have identified no other activity that would connect their specific claims to Illinois. Many nonresident plaintiffs initiated duplicate actions in California, indicating that the interests of judicial economy are not furthered by permitting their claims to proceed in Illinois. A corporation’s continuous activity of some sort within a state is not enough to render the corporation subject to suits unrelated to that activity. View "Rios v. Bayer Corp." on Justia Law