Justia Constitutional Law Opinion Summaries

Pingelton was charged with criminal sexual assault on victims who were 16 years old. The emergency medicine physicians who examined the victims testified that they had no opinion as to whether either victim was sexually assaulted. The appellate court affirmed his convictions. Pingelton pro se filed a postconviction petition alleging ineffective assistance of both trial and appellate counsel, citing failure to object to the presentation of improper expert testimony by the physicians. The prosecution’s motion to dismiss was served on Pingelton’s appointed counsel. Almost two years later, postconviction counsel moved to withdraw, arguing that Pingelton’s claims could not be supported as a matter of law and that the record revealed no other meritorious issues. Pingelton requested that the court allow him to amend his petition and proceed. At a “status” hearing, the state and postconviction counsel appeared personally. Pingelton appeared via telephone. The court granted counsel’s motion to withdraw and dismissed, finding that none of Pingelton’s allegations indicated that he had received “unreasonable” assistance from his attorneys.The Appellate Court affirmed. The Illinois Supreme Court affirmed. Pingelton’s right to procedural due process was violated when the court dismissed his postconviction petition without affording him adequate notice and a meaningful opportunity to be heard. However, Pingelton’s claims lack merit, so he did not present a substantial showing of a constitutional deprivation at trial or on direct appeal. View "People v. Pingelton" on Justia Law

In 1993, Kastman was charged with misdemeanor offenses based on acts of public indecency involving children and disorderly conduct. The state’s attorney initiated a civil commitment proceeding against Kastman under the Sexually Dangerous Persons Act (725 ILCS 205/0.01). Evidence indicated that Kastman suffered from pedophilia, antisocial personality disorder, exhibitionism, and alcohol dependency. Kastman was found to be a sexually dangerous person, and the circuit court granted the petition. In 2016, Kastman was granted conditional release from institutional care.In 2020, he sought financial assistance. Kastman asserted that he was unemployed, disabled, and could not afford his $300 monthly treatment costs and the $1800 monthly rent for housing that complied with the Sex Offender Registration Act. The circuit court of Lake County ordered the Department of Corrections to pay a portion of Kastman’s monthly expenses. The appellate court and Illinois Supreme Court affirmed. The statutes indicate that a sex offender’s ability to pay is a relevant consideration in deciding who should bear the expense of treatment costs; without a clear statutory directive, the legislature is not presumed to have intended that only financially stable individuals are eligible for conditional release. Financial instability and the need for supervision to protect the public are not the same things. View "People v. Kastman" on Justia Law

Jackson was convicted of first-degree murder and attempted armed robbery. After the jury returned its signed verdict forms in open court, Jackson’s attorney asked the court to poll the jury. The circuit court then asked 11 of the 12 jurors whether the verdicts reflected on the verdict forms were their verdicts. All of the 11 jurors who were questioned confirmed that the signed verdict forms accurately reflected their verdicts. The circuit court dismissed the jury without polling the twelfth juror. Jackson’s attorney failed to object to the error and did not include the error in a posttrial motion.Jackson raised the error for the first time on direct appeal. The appellate court held that the error in polling the jury constituted structural error that called into question the integrity of the judicial process, excused the forfeiture under the second prong of Illinois’s plain error rule, and reversed the conviction. The Illinois Supreme Court reinstated the conviction. A procedure that is not required in every criminal jury trial cannot be logically categorized as an essential element of every criminal jury trial on par with the jury trial oath; no U.S. Supreme Court precedent suggests that a criminal defendant is denied the fundamental right to juror unanimity when jury polling does not take place or when there is an error in the jury polling process. View "People v. Jackson" on Justia Law

Noland and Clayborne (plaintiffs) are former members of the General Assembly who voted for laws that reduced legislators’ salaries. After leaving office, plaintiffs filed suit, alleging that the reductions violated article IV, section 11, of the Illinois Constitution (Legislative Salary Clause) and sought a writ of mandamus compelling the Illinois Comptroller to pay them and all affected legislators their disputed salaries. The Cook County circuit court found that the affirmative defenses of laches and waiver failed as a matter of law and that the statute of limitations defense lacked merit. The court also found that, although plaintiffs were entitled to relief for themselves, they could not obtain relief on behalf of nonparty legislators. The court found that the laws at issue were facially unconstitutional and that the plaintiffs were entitled to mandamus relief.The Illinois Supreme Court reversed. The plaintiffs, suing in their individual and not in their official capacity, have “slept on their rights” and are estopped from bringing their claims. The "public was misled by these plaintiffs," who waited to file their action until eight years elapsed following the enactment of the fiscal 2010 Salary Reduction Laws and all subsequent enactments. The court vacated findings that the Salary Clause prohibits mid-term changes in legislators’ salaries and awards of $71,507.43 for Noland and $104,412.93 for Clayborne. View "Noland v. Mendoza" on Justia Law

The building at 1572 North Milwaukee Avenue in Chicago is owned by the Corporation. Strauss was the Corporation’s president. Double Door Liquors, a music venue, was a tenant in the building. Numerous difficulties arose with Double Door, including lease violations, excessive noise levels, illegal drug use, alcohol abuse, and property damage. The Corporation terminated Double Door’s lease and filed an eviction action, which led to Double Door’s eviction. Subsequently, Chicago enacted a zoning ordinance that changed the types of establishments that were allowed in the building.Strauss challenged the zoning ordinance and certain conduct of alderman Moreno and the city that occurred before the zoning ordinance was enacted. The appellate court and Illinois Supreme Court affirmed the dismissal of the complaint. The court found that the plaintiffs had standing despite a misnomer in the complaint and that not all of the claims were moot, despite the sale of the building. Because Moreno is not liable for injuries resulting from his conduct due to discretionary immunity under the Local Governmental and Governmental Employees Tort Immunity Act, 745 ILCS 10/2-10, Chicago is likewise not liable. The court declined to address the constitutionality of the zoning ordinance that applies to one piece of property that the Corporation has sold. View "Strauss v. City of Chicago" on Justia Law

In 1999, Riley was shot and killed in Chicago. Coleman made a statement to police that she saw Blalock, whom she knew from grammar school, with his hand out a car window, shooting in Riley’s direction. Coleman stated that no threats or promises had been made to her and that she had been allowed to make corrections to her statement. Blalock gave a handwritten statement confessing to the shooting. Before trial, defense counsel filed a motion to suppress, alleging that Blalock's statement was the result of physical coercion by detectives, who slapped and yelled at him, threatened him, and cut or sliced his fingernails. At trial, Coleman recanted her statement, claiming that police had struck her with pens and her statement had not been freely given.Convicted of first-degree murder, Blalock was sentenced to 40 years’ imprisonment. In 2016, Blalock sought leave to file a second successive postconviction petition, claiming that newly discovered evidence showed that the officers who interrogated him had engaged in a pattern and practice of police brutality. The appellate court and Illinois Supreme Court affirmed the denial of that petition. Blalock failed to establish prejudice by showing that the claim not raised during the initial proceeding so infected the trial that the resulting conviction or sentence violated due process, 725 ILCS 5/122-1(f). Blalock’s trial testimony indicated that he fabricated his statement to appease the detectives and assistant state’s attorney, not because of physical abuse, which contradicts the abuse allegations contained in the post-conviction petition. View "People v. Blalock" on Justia Law

In 2013, Craig (age 49) executed an Illinois statutory short-form health care power of attorney, appointing his mother as his agent. In 2016, Craig was hospitalized at McFarland after being charged with burglary and found unfit to stand trial. In 2018, a McFarland psychiatrist sought to involuntarily administer psychotropic medications to Craig under the Mental Health Code, 405 ILCS 5/2-107. Craig alleged that decisions on his medical treatment rested with his agent. A psychiatrist testified that Craig was diagnosed with schizoaffective disorder, bipolar type, when he was 25 years old and had been experiencing hallucinations with symptoms of paranoia, inability to sleep, poor impulse control, hypersexuality, physical aggression, and psychomotor agitation; Craig had no understanding of his mental illness and lacked the capacity to make rational treatment decisions. She opined that the benefits of the medications outweighed the potential risks. Without treatment, Craig was unable to live outside a hospital. Craig’s 82-year-old mother declined to consent, believing that the medications caused brain damage, made Craig “like a zombie,” and made him look “like a man without a head.”The trial court granted the petition for involuntary administration of psychotropic medication for a period not to exceed 90 days. The appellate court and Illinois Supreme Court affirmed. The Mental Health Code, which includes strict standards for an order permitting involuntary administration of psychotropic medications, provides a narrow exception to an agent’s authority to make a principal’s health care decisions. View "In re Craig H." on Justia Law

Lewis was charged with involuntary sexual servitude of a minor (720 ILCS 5/10-9(c)(2)), traveling to meet a minor (11- 26(a)), and grooming (i11-25(a)). He asserted the defense of entrapment. Convicted, he was sentenced to six years’ imprisonment. The appellate court reversed the conviction, holding that defense counsel’s cumulative errors rendered the proceeding unreliable under Strickland v. Washington.The Illinois Supreme Court affirmed the remand for a new trial. Defense counsel was ineffective in presenting his entrapment defense where he failed to object to the circuit court’s responses to two jury notes regarding the legal definition of “predisposed,” object to the prosecutor’s closing argument mischaracterizing the entrapment defense and the parties’ relevant burdens of proof, and present defendant’s lack of a criminal record to the jury. View "People v. Lewis" on Justia Law

In 2015, Aljohani was indicted on five counts of first-degree murder in connection with the stabbing death of Talal and one count of armed robbery. The circuit court denied a motion to suppress evidence. The court concluded that the officers’ entry into an apartment fell “squarely within the community caretaking function.” In 2018, Aljohani was convicted and sentenced to 23 years in prison. The appellate court affirmed, citing the emergency aid exception to the warrant requirement.The Illinois Supreme Court affirmed, finding that the evidence was sufficient to prove guilt beyond a reasonable doubt. The police officers had reasonable grounds to believe an emergency existed, having responded to a 911 call about a suspected battery in progress and spoken to a witness, who was “adamant” that someone was seriously hurt. The officers saw an apartment door “wide open,” received no response, and found the victim unresponsive on a bed. The totality of the circumstances at the time of entry provided an objective, reasonable basis for believing someone was injured inside the apartment. View "People v. Aljohani" on Justia Law

In 2017, Brown was charged with violating section 2(a)(1) of the Firearm Owners Identification Card Act (430 ILCS 65/2(a)(1)), which requires a person who possesses a firearm in Illinois to have a Firearm Owners Identification (FOID) card issued by the State Police. Brown challenged section 2(a)(1) as unconstitutional as applied under the Second Amendment. The circuit court dismissed the charge, finding that the legislature did not intend for the FOID Act to apply in a person’s home because “such an interpretation would lead to absurd and unworkable results.”The Illinois Supreme Court stated: “The circuit court’s ruling that section 2(a)(1) … is unconstitutional as applied was not necessary to the resolution of this case. Therefore, we remand this cause … direct that the order … be vacated." When the cause was remanded, the matter proceeded before a new judge, who adopted the reasoning of an Illinois Supreme Court dissent and again found the section unconstitutional as applied.The Illinois Supreme Court again vacated and remanded. The circuit court had no authority to set aside the directions on remand and enter a different order. The mandate was “precise and unambiguous.” On remand, “the circuit court shall not entertain any motion from any party, nor take any action other than entering the modified order.” View "People v. Brown" on Justia Law