Justia Constitutional Law Opinion Summaries

Hutt was convicted of obstructing justice and driving under the influence of alcohol (DUI). The Fourth District affirmed. Hutt argued that the trial court improperly denied him a jury trial in the DUI case and that the evidence was insufficient to find him guilty of obstructing justice. Hutt executed a written jury waiver and was admonished with regard to his right to a jury trial. Although all five cases against him were set for a jury trial on the day of the waiver, the written waiver did not reference the DUI case number. The pretrial conference order referenced all five case numbers, indicated that Hutt had waived a jury trial, and removed the entire cause from the jury docket. Thereafter, when all five cases were called for a status hearing, Hutt's counsel stated that Hutt had previously waived his right to a jury trial. The trial court addressed Hutt, who did not challenge the waiver but, rather, explained why he had waived his right to a jury trial. At subsequent court proceedings, Hutt never objected to a bench trial in the DUI caseThe Illinois Supreme Court affirmed Hutt’s DUI conviction but reversed his obstructing justice conviction. Hutt’s refusal or recalcitrance to comply with the police officers and the search warrant to obtain his blood or urine did not meet the definition of “conceal” for the obstruction charge. View "People v. Hutt" on Justia Law

Romeoville police responded to a call that a residential security alarm had been activated. Prince came to the door and stated “Jessica” lived there but was out of town. He refused to give his name or identification. Prince was arrested and taken to the police station. Another officer remained at the residence, spoke to a friend of Jessica’s, and obtained Prince’s social media username. From this, the officer determined Prince’s name and learned there was an active warrant out for his arrest. The warrant had been issued in error and was later vacated. Prince initially refused to be fingerprinted or to take a booking photo, stating his name was “Sean Williams” and giving an incorrect birth date. Prince agreed to allow the police to fingerprint and photograph him “more than minutes,” after arriving at the station.At trial, the parties did not raise, and the court did not address “material impediment” as an element of obstruction of justice by furnishing false information (720 ILCS 5/31-4(a)(1). A jury convicted Prince. On appeal, the state conceded that the evidence presented was insufficient as a matter of law where the state offered no evidence on the “material impediment” element. The appellate court remanded for a new trial, finding double jeopardy did not bar retrial. The Illinois Supreme Court reversed. Retrial is prohibited. There was no trial error, or anything similar, that prevented the state—which bore the burden of proof—from introducing evidence on the issue of material impediment. View "People v. Prince" on Justia Law

In 2008, Graefnitz went with Wilson and Moore to buy drugs. Graefnitz was shot in the back and died from his wounds. Wilson was then 14 years old. The court granted a transfer motion, concluding that charging Wilson in the juvenile justice system “with the hope that this minor will somehow be transformed into a non-violent law-abiding citizen ready for release in society at age 21” would not serve the public interest nor the interest of justice. Wilson was convicted of first-degree murder and attempted armed robbery. In response to a special interrogatory, the jury found that Wilson did not personally discharge the weapon that caused Graefnitz’s death. The PSI consisted of more than 200 pages of reports and supporting documents, including information about Wilson’s troubled background, mental disabilities, substance abuse, criminal history, and medical diagnoses. The court sentenced Wilson to 55 years’ imprisonment for murder (which included a 15-year firearm enhancement), to be served at 100%, and a consecutive four years for attempted armed robbery.Wilson sought leave to file a successive postconviction petition challenging his sentence as violating the eighth amendment by imposing a de facto life sentence without a finding of permanent incorrigibility or specifically addressing the attendant characteristics of youth discussed in the Supreme Court’s 2012 "Miller" decision. The Illinois Supreme Court reversed a decision that vacated Wilson’s sentence. The sentencing court reviewed the entire PSI, which contained extensive evidence regarding Wilson’s developmental age, maturity, and other circumstances, and announced several times that Wilson was young. Wilson received the constitutionally required procedure under Miller. View "People v. Wilson" on Justia Law

Conway was convicted as being an armed habitual criminal following a 2015 Chicago shooting, 720 ILCS 5/24-1.7. Conway challenged the sufficiency of the evidence and the identification testimony of a police officer. The appellate court found that the evidence was sufficient to convict Conway but nonetheless reversed and remanded for a new trial due to the trial court’s pronounced bias in favor of police testimony. The court had stated: I find that the officer did have a unique opportunity to view the shooter … the officer’s testimony with regard to the identity of the shooter was in fact clear, credible, and convincing… he was not in a situation where his perception might have been affected … he is a professional … which I think is something that I can take into consideration as compared to an individual who’s never had any such training.The Illinois Supreme Court reversed in part. The trial court’s comments regarding the officer’s training related to the court’s credibility determination and as nothing else in the record indicates that the trial court displayed favoritism for police testimony. View "People v. Conway" on Justia Law

In 1983, Prante was convicted of a strangulation murder. The appellate court rejected Prante’s claim that the state’s expert testimony concerning bite marks should not have been admitted. In 1993, Prante filed a postconviction petition, alleging ineffective assistance of counsel and a due process claim concerning “material misrepresentation of evidence” relating to blood found at the crime scene.” The circuit court dismissed the petition as untimely. In 2002, Prante filed an unsuccessful petition arguing that his sentence violated Apprendi. In 2017, Prante successfully sought DNA and fingerprint testing (725 ILCS 5/116-3). No interpretable DNA profiles were obtained, and no match was found for the fingerprint.In 2018, Prante sought leave to file a successive postconviction petition that argued actual innocence, a due process claim alleging that his trial was rendered fundamentally unfair by the admission of bite mark analysis evidence, and ineffective assistance of trial and appellate counsel. Prante asserted that recent scientific studies had discredited the forensic bite mark opinion testimony. The Illinois Supreme Court found that Prante is not entitled to file either the due process or the actual innocence claim. Without any allegation that the state knowingly used the false bite mark testimony or failed to exercise diligence to discover that the testimony was false, Prante has not pled a cognizable due process claim under Illinois law. Prante has not met the high standard for setting forth a colorable claim of actual innocence. View "People v. Prante" on Justia Law

Moore and Williams, both sentenced to life in prison without parole for separate murders committed when they were 19 years old, appealed from judgments denying them leave to file successive postconviction petitions challenging their sentences. The Fourth District affirmed the judgment against Moore; the Second District reversed the judgment against Williams.The Illinois Supreme Court held that neither Moore nor Williams sufficiently pled cause for filing their successive postconviction petitions. The Supreme Court’s 2012 Miller v. Alabama decision did not change the law applicable to discretionary sentences imposed on young adult offenders, it does not provide cause for Moore and Williams to file their proposed successive postconviction petitions. Moore failed to allege facts that could support a finding that his brain development at the time of the crime required the court to treat him as a juvenile offender. View "People v. Moore" on Justia Law

Addison was convicted, in absentia, of unlawful possession of a motor vehicle, unlawful possession of a converted motor vehicle, forgery, and two counts of theft, arising out of his alleged use of counterfeit money to purchase a motorcycle, and was sentenced to 15 years’ imprisonment. Having failed to appear for trial, he was subsequently arrested.Addison’s appellate counsel did not file a brief and determined that there are no meritorious issues, except concerning credit that should be applied toward the prison sentences. Addison filed a postconviction petition, contending that trial and appellate counsel were deficient. Appointed postconviction counsel filed an amended petition, alleging trial counsel was ineffective for failing to file a motion to suppress based on improper Miranda warnings, for failing to object to expert testimony regarding counterfeit currency when no expert was disclosed, and for failing to argue sufficiency of the evidence where there were discrepancies; and that the court erred in giving an accountability instruction. The petition did not assert ineffective assistance of appellate counsel. The trial court dismissed the petition.Addison appealed, arguing that postconviction counsel rendered unreasonable assistance in failing to argue ineffective assistance of appellate counsel. The Illinois Supreme Court agreed. Addison did not forfeit collateral review of his conviction by failing to appear at trial. While any postconviction claims that could have been raised on direct appeal are generally forfeited that forfeiture could have been overcome by framing the issues as ineffective assistance of appellate counsel for failing to raise the issues on direct appeal. The appellate court properly remanded for compliance with Illinois Supreme Court Rule 651(c) without considering the merits. View "People v. Addison" on Justia Law

In March 2020, the Illinois Supreme Court began entering a series of emergency administrative orders to address disruptions to the court system caused by the outbreak of the COVID-19 pandemic. Certain orders authorized the state’s circuit courts to toll the time restrictions set forth in section 103-5(a) of the Code of Criminal Procedure, 725 ILCS 5/103-5(a), the speedy-trial statute. Mayfield was tried and convicted in accordance with the administrative orders’ tolling provisions but after the speedy-trial term prescribed by section 103-5(a) had run.Mayfield argued that the court’s administrative orders violated the Illinois Constitution’s separation-of-powers clause by infringing on the General Assembly’s legislative authority. The Illinois Supreme Court affirmed his conviction. Because section 103-5(a) involves the scheduling of trials, the statute is a matter of court procedure and within the court’s constitutional authority over all state courts. Where, as here, a statute and a supreme court rule governing court procedure cannot be reconciled, the statute must give way to the rule. The orders that tolled the speedy-trial statute did not violate the separation-of-powers clause. View "People v. Mayfield" on Justia Law

During a pat-down search of Brown, Chicago officers recovered a loaded handgun from his pocket and packets of a suspected narcotic from the driver’s seat of his car. Brown was charged with being an armed habitual criminal and possessing a controlled substance. Two attorneys appeared on Brown’s behalf. The court questioned the venire members in panels and conferred with the attorneys at a sidebar to discuss objections. The court held eight sidebars off the record before announcing that a jury had been selected. The judge then went back on the record, outside the presence of the jury, and explained the challenges for cause and for peremptory challenges. The jury found Brown guilty of being an armed habitual criminal. In his motion for a new trial, Brown did not challenge the sidebars. On appeal, Brown argued that he was deprived of his constitutional right to be present at a critical stage of the proceeding and asserted that his defense counsel was ineffective for failing to object to the process where jurors were challenged at sidebars without Brown himself being present.The appellate court and Illinois Supreme Court affirmed his conviction. Brown did not establish prejudice; he failed to show that he was not tried by an impartial jury. Brown was present in the courtroom for all the questioning of the venire members; the record is silent as to whether Brown talked with counsel about venire members before the sidebars. Without any evidence that counsel failed to represent Brown’s interests at the sidebars, there is no basis to conclude that counsell rendered deficient performance by failing to object to the procedure. View "People v. Brown" on Justia Law

In 1993, Clark entered Catlin's Galesburg apartment to commit robbery. Clark was 24 years old; Catlin was 89. Clark killed Catlin by cutting her throat, then robbed the apartment. Clark pled guilty but mentally ill to first-degree murder and robbery. Clark suffered from antisocial personality disorder, borderline personality disorder, and fetal alcohol syndrome. He had an IQ of 79 and the intellectual ability of a 13-14-year-old; he had been severely abused as a child and had an extensive criminal history. Clark was sentenced to 90 years of imprisonment for the murder, with a consecutive 15-year prison sentence for the robbery. The appellate court affirmed. In 2001 and 2012 Clark filed unsuccessful post-conviction petitions.In a 2018 motion for leave to file a successive postconviction petition, Clark challenged the constitutionality of his sentence as inconsistent with the Illinois Constitution's proportionate penalties clause. Clark argued that his sentence was the functional equivalent of a life sentence and that the circuit court failed to give sufficient weight to the characteristics of his intellectual disabilities and his young age as mitigation factors. The appellate court and Illinois Supreme Court affirmed the denial of relief.The proportionate penalties clause requires penalties to be determined with the objective of restoring the offender to useful citizenship and provides a limitation on penalties beyond those afforded by the eighth amendment. Precedent does not establish “cause” for relaxing the res judicata doctrine with respect to the issues Clark raised, which were decided on direct appeal. Clark also cannot establish prejudice under the cause-and-prejudice test by advancing a challenge to his sentence as it relates to his intellectual disabilities. “Neurological development was not a prospect for” Clark. View "People v. Clark" on Justia Law