Justia Constitutional Law Opinion Summaries

In 1997, Pipes was found dead, with stab wounds to her neck and head; semen was discovered with vaginal swabs. There was no evidence of rape. Above the bathtub in which she was found, there was a palm print left in Pipes’s blood. In 2004, the state obtained a grand jury subpoena for the Illinois Department of Corrections to take palm and fingerprints of Boston, then incarcerated on a life sentence, who was Pipes' ex-boyfriend. After prints were taken, a warrant issued for defendant’s DNA. A test showed that the DNA profile extracted from the semen was consistent with having originated from Boston. In 2005, the state obtained an indictment. Boston unsuccessfully moved to quash the subpoena and suppress the palm print evidence, arguing that the state improperly used the grand jury to obtain the subpoena and to supplement a police investigation in violation of his fourth amendment rights, and violated grand jury procedures by failing to return the fingerprint card to the grand jury. The appellate court and Illinois Supreme Court affirmed, finding no basis to conclude that this was a “rogue police investigation.” The information provided to the grand jury was sufficiently tied to Boston to hold that there was individualized suspicion to warrant the subpoena. View "People v. Boston" on Justia Law

Ligon, convicted of aggravated vehicular hijacking with a dangerous weapon, other than a firearm (AVH/DW), a Class X felony, under 720 ILCS 5/18-4(a)(3), (b), was adjudged to be an habitual criminal and sentenced to a term of mandatory life imprisonment under 720 ILCS 5/33B-1(a), (e). He filed a petition for relief from judgment under 735 ILCS 5/2-1401), contending that the sentence violated the proportionate penalties clause of the Illinois Constitution. The trial court dismissed defendant’s petition sua sponte. The appellate court reversed. The Illinois Supreme Court granted the state leave to appeal and reinstated the judgment of the circuit court, rejecting the proportional it claim because AVH/DW and armed violence while armed with a category III weapon (720 ILCS 5/33A-2(a), 33A-1(c)(3)). Ligon was properly convicted of AVH/DW while using a BB gun as a common-law dangerous weapon of the third type. It is irrelevant that the indictment used the term “bludgeon” instead of BB gun; the two are interchangeable under the statute. View "People v. Ligon" on Justia Law

Defendant was driving a van registered to a woman named Chattic in the city of Sterling. Sterling police officer Bland pulled the van over because there was a warrant out for Chattic’s arrest. Bland was unable to see the driver of the van until after he had pulled the vehicle over. Upon approaching, Bland saw defendant was a man and could not have been Chattic. Bland asked defendant for a driver’s license and proof of insurance before explaining the reason for the stop. Defendant responded that he did not have a driver’s license and Bland cited him for driving while his license was suspended. The Illinois Supreme Court affirmed suppression of the evidence, finding that Bland’s license request impermissibly prolonged the seizure of defendant and the van. The U.S. Supreme Court vacated and remanded. On remand, the Illinois Supreme Court reversed. The U.S. Supreme Court’s 2015 decision in Rodriguez makes clear that a driver’s license request of a lawfully stopped driver is permissible irrespective of whether that request directly relates to the purpose for the stop. As a result, Officer Bland’s request for defendant’s license did not violate the fourth amendment by prolonging the stop. View "People v. Cummings" on Justia Law

A search warrant was served at a home belonging to Chambers’ mother. He was found inside, along with a large quantity of cocaine, cash, weapons, and ammunition. The Cook County circuit court denied his repeated requests for a Franks hearing. He was convicted of armed violence and unlawful possession of a controlled substance with intent to deliver and sentenced to consecutive terms of 25 and 45 years’ imprisonment. The appellate court held that the trial court should have conducted a Franks hearing and remanded for determination of whether the search warrant was properly issued, stating that the informant’s appearance and testimony before an issuing judge is “but one factor to consider in determining whether to grant a Franks hearing, but it does not categorically preclude the court from holding a Franks hearing.” The Illinois Supreme Court affirmed. Chambers made a substantial preliminary showing that a false statement was intentionally, knowingly, or recklessly included in the warrant affidavit; it is irrelevant that the officer’s suspicions about the presence of guns and drugs at the address turned out to be well-founded. View "People v. Chambers" on Justia Law

Sanders was convicted of the 1992 first-degree murder and aggravated kidnapping of Cooks. Sanders was sentenced to concurrent prison terms of 60 and 15 years. Bingham, May, and Barfield were convicted in separate trials. In 2010, Sanders filed a second successive postconviction petition, alleging actual innocence. Despite the absence of any motion for leave to file the successive petition, the circuit court allowed it and advanced it to the second stage of proceedings. The court then dismissed the petition. The appellate court affirmed. The Illinois Supreme Court affirmed, finding purported new evidence and a recantation “not so conclusive in character as would probably change the result on retrial.” View "People v. Sanders" on Justia Law

Defendant was convicted of first-degree murder in the deaths of Coleman, a 68-year-old man shot multiple times at his Chicago home in a botched robbery in 2005, and Stanley, defendant’s alleged coconspirator, gunned down in an alley the next day. Defendant’s statements in taped police interrogation were admitted as evidence against him at trial, after he sought suppression of those statements, arguing they were involuntary due to police questioning him off-camera and without Miranda rights, and due to physical coercion from handcuffs kept on him an excessively long time. The appellate court concluded the confession should have been suppressed, due to doubts it was voluntary, based on defendant’s age (then 19), educational level, sleep and food deprivation, prior substance abuse, deceptive conduct by police, length of interrogation, coercive atmosphere, lack of experience with the criminal justice system, and use of marijuana while in custody. The Illinois Supreme Court remanded. While defendant adequately preserved the broad issue of voluntariness of his confession, his arguments on appeal were almost entirely distinct from his arguments before the trial court. The drastic shift in factual theories deprived the state of the opportunity to present evidence. A court of review could not be confident in the adequacy of this record to address those arguments. View "People v. Hughes" on Justia Law

In 2011, defendant was convicted under the aggravated unlawful use of a weapon statute (AUUW) (720 ILCS 5/24-1.6(a)(1), (a)(3)(A)) and sentenced to 10 years’ imprisonment. That statute was found to be unconstitutional in 2013 (Aguilar case). The appellate court affirmed defendant’s conviction, finding that, in Aguilar, the Illinois Supreme Court limited its finding of unconstitutionality to the “Class 4 form” of the offense and that the “Class 2 form,” applicable to felons, like defendant, was constitutional and enforceable. The Illinois Supreme Court reversed. A “Class 2 form” of AUUW does not exist. There is only one offense of AUUW based on section 24-1.6(a)(1)(a)(3)(A) and a prior felony conviction is not an element of that offense. A prior felony conviction is a sentencing factor which elevates the offense from a Class 4 felony to a Class 2 felony. On its face, the provision constitutes a flat ban on carrying ready-to-use guns outside the home and amounts to a wholesale ban on the exercise of a personal right that is specifically guaranteed by the U.S. Constitution, as construed by the Supreme Court. Because the prohibition is not limited to a particular subset of persons, such as felons, the statute, as written, is unconstitutional on its face. View "People v. Burns" on Justia Law

The issue before the Illinois Supreme Court in this case was a circuit court’s order declaring certain sections of the aggravated unlawful use of a weapon (AUUW) statute as unconstitutional. The circuit court found that sections 24-1.6(a)(1), (a)(3)(C) and (a)(2), (a)(3)(C) of the AUUW statute, which were based on defendant’s lack of a Firearm Owner’s Identification Card (FOID card), violated the proportionate penalties clause of the Illinois Constitution. The court determined that the offense of AUUW based on the lack of a FOID card was identical to a violation of the FOID Card Act, and since the penalties for violating the two statutes were different, the court declared the AUUW statute unconstitutional and dismissed the charges against defendant. The Supreme Court concluded that the offense of AUUW based on the lack of a FOID card and a violation of the FOID Card Act do not have identical elements and thus, there can be no proportionate penalty violation. The circuit court’s judgment was reversed and the case remanded for reinstatement of the charges against defendant. View "Illinois v. Williams" on Justia Law

The issue before the Supreme Court in this appeal was whether the “void sentence rule,” should be abandoned. Defendant Steven Castleberry was convicted on two counts of aggravated criminal sexual assault based on separate acts of oral and vaginal contact with the victim. At sentencing, the State argued that defendant was subject to a mandatory 15-year sentencing enhancement on each of the two counts because the crimes had been committed by defendant while he was armed with a firearm. When added to the mandatory minimum term of 6 years’ imprisonment for each offense, this meant, according to the State, that defendant was subject to a mandatory minimum term of 21 years’ imprisonment on each count. The circuit court disagreed with the State regarding the application of the 15-year enhancement, concluding that the legislature had intended the enhancement to be applied only once under the circumstances presented. The circuit court sentenced defendant to a 9-year term of imprisonment on each count, adding the 15-year enhancement to only one of the counts. The two sentences were ordered to run consecutively, for a total term of 33 years’ imprisonment. On appeal, defendant did not challenge the appellate court’s affirmance of his convictions. Instead, defendant argued that the appellate court erred when it held that the sentence imposed without the statutory enhancement was void. Defendant contended that the rule relied upon by the appellate court (that a sentence which does not conform to statutory requirements was void) was no longer valid in light of recent Illinois Supreme Court decisions and, thus, could not provide a basis for the appellate court to reverse the circuit court’s sentencing order. After review, the Court concluded that its recent decisions indeed undermined the rationale behind the rule to the point that the rule could no longer be considered valid. The Court therefore abolished the rule. View "Illinois v. Castleberry" on Justia Law

In this case, defendant Jorge Guzman argued that the Illinois Supreme Court’s decision in “Illinois v. Delvillar,” (235 Ill. 2d 507 (2009)), should have been overturned based on the United States Supreme Court’s later decision in “Padilla v. Kentucky,” (559 U.S. 356 (2010)). In “Delvillar,” the Illinois Court examined the impact of the failure to give a statutory admonishment on the potential immigration consequences of entering a guilty plea. The Court concluded that the failure to admonish did not affect the voluntariness of the plea, and defendants wishing to withdraw their pleas on that basis were required to demonstrate prejudice or a denial of justice. After review of defendant Guzman’s arguments that the trial court erred in denying him the ability to withdraw his guilty plea, the Supreme Court affirmed the denial. View "Illinois v. Guzman" on Justia Law