Justia Criminal Law Opinion Summaries
Articles Posted in Supreme Court of Illinois
People v. Cooper
The defendant, Tyrell Derrious Cooper, was charged with aggravated battery, aggravated discharge of a firearm, and unlawful possession of a weapon by a felon. The State filed a petition to deny his pretrial release, arguing that his release posed a threat to the community. The circuit court of Rock Island County held a pretrial detention hearing more than 48 hours after the defendant's first appearance, which the defendant argued was untimely.The Appellate Court, Fourth District, agreed with the defendant, vacated the circuit court's detention order, and remanded the case for a hearing to determine the least restrictive conditions for the defendant's pretrial release. The appellate court held that the pretrial detention hearing was held outside the 48-hour time frame required by statute and that the appropriate remedy was to remand for a new hearing on pretrial release conditions.The Supreme Court of Illinois reviewed the case and reversed the appellate court's judgment. The court held that the 48-hour timing requirement for pretrial detention hearings is directory, not mandatory, meaning that failure to comply does not automatically invalidate the detention order. The court found that the statute did not specify a consequence for noncompliance and that the rights protected by the statute would not generally be injured by a directory reading. The court also noted that the defendant did not demonstrate any prejudice from the brief delay in holding the hearing. Therefore, the circuit court's order denying pretrial release was affirmed. View "People v. Cooper" on Justia Law
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Criminal Law, Supreme Court of Illinois
People v. Cousins
Antonio Cousins Jr. was charged in Peoria County with aggravated discharge of a firearm and unlawful possession of a weapon by a felon in one case, and being an armed habitual criminal, unlawful possession of a weapon by a felon, and unlawful possession of firearm ammunition by a felon in another case. He remained in custody with a bond set at $150,000. Cousins waived his right to counsel and filed several pro se motions, including for pretrial release under the Pretrial Fairness Act. The State filed petitions to deny pretrial release, asserting that Cousins posed a threat to the community and had a high likelihood of flight.The circuit court of Peoria County denied Cousins' motions for pretrial release, citing his prior felony convictions and the nature of the current charges. The court found by clear and convincing evidence that Cousins posed a real and present threat to the community and that no conditions could mitigate this threat. The Appellate Court, Fourth District, found that the circuit court erred in detaining Cousins because the State failed to meet its burden of proving that no condition or combination of conditions could mitigate the threat posed by his release. The appellate court reversed the detention order and remanded for a new detention hearing.The Supreme Court of Illinois reviewed the case and agreed with the appellate court that the State failed to meet its burden of proof regarding the conditions element. The court held that when the State fails to meet its burden, the proper remedy is to remand for a hearing on the least restrictive conditions of release, rather than a new detention hearing. The court affirmed in part and reversed in part the appellate court's judgment and remanded the case to the circuit court for a hearing on the conditions of release. View "People v. Cousins" on Justia Law
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Criminal Law, Supreme Court of Illinois
Village of Lincolnshire v. Olvera
A 16-year-old high school student was convicted of driving under the influence (DUI) of cannabis following a bench trial in the circuit court of Lake County, Illinois. The student was also convicted of improper lane usage, possession of cannabis, and reckless conduct under local ordinances. The incident occurred during a driver's education class, where the instructor noticed erratic driving behavior and reported it to school officials. A subsequent search revealed a marijuana cigarette, and field sobriety tests conducted by a school resource officer and later at the police station indicated impairment.The student appealed to the Appellate Court, Second District, arguing that the Village of Lincolnshire improperly prosecuted him without providing proof of written permission from the State's Attorney, as required by the Illinois Vehicle Code. The student also contended that the evidence was insufficient to prove DUI beyond a reasonable doubt. The appellate court affirmed the conviction, finding no requirement for the Village to submit proof of its authority to prosecute into the trial record and determining that the evidence was sufficient to support the conviction.The Illinois Supreme Court reviewed the case, focusing on whether the Village needed to establish its written permission to prosecute in the trial record and whether the evidence was sufficient to prove the student was under the influence to a degree that rendered him incapable of driving safely. The court held that the statute did not require the Village to submit its written permission into the record and that the failure to do so did not constitute plain error. Additionally, the court found that the evidence, including testimony and field sobriety tests, supported the conviction beyond a reasonable doubt. The Illinois Supreme Court affirmed the appellate court's judgment, upholding the student's conviction. View "Village of Lincolnshire v. Olvera" on Justia Law
People v. Wallace
In 2019, Deshawn Wallace was arrested after police found a handgun in his jacket during a traffic stop. Wallace did not have a Firearm Owner’s Identification (FOID) card or a concealed carry license. He was charged with being an armed habitual criminal, among other weapon-related offenses. Wallace had prior felony convictions: a 2008 armed robbery committed when he was 17 and a 2015 unlawful use of a weapon by a felon.The Cook County circuit court denied Wallace’s motion to suppress the handgun evidence. At a bench trial, the court found Wallace guilty of all charges and merged them into a single conviction for being an armed habitual criminal, sentencing him to six years in prison. Wallace appealed, arguing the trial court erred in denying his motion to suppress and that his 2008 conviction should not count as a predicate offense for the armed habitual criminal charge because he was 17 at the time.The appellate court rejected Wallace’s arguments, affirming his conviction. The court held that the armed habitual criminal statute only requires proof of two prior qualifying felony convictions, regardless of how those offenses would be treated under current laws.The Illinois Supreme Court reviewed the case and affirmed the appellate court’s decision. The court held that Wallace’s 2008 armed robbery conviction could serve as a predicate offense for the armed habitual criminal charge. The court reasoned that the statute’s language does not incorporate the current juvenile adjudication scheme and that the legislature’s use of present tense terms does not imply such an incorporation. The court also distinguished this case from People v. Stewart, noting that the armed habitual criminal statute had not been amended to include age considerations for predicate offenses. View "People v. Wallace" on Justia Law
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Criminal Law, Supreme Court of Illinois
People v. Dyas
The defendant, Robert D. Dyas, pleaded guilty to unlawful possession with intent to deliver more than 900 grams of methamphetamine. He later moved to withdraw his plea, but the Bureau County circuit court denied the motion. Dyas filed a motion to reconsider, and while it was pending, he filed a notice of appeal. He then moved to dismiss the appeal as premature, which the appellate court granted, dismissing the appeal. The trial court subsequently denied the motion to reconsider, and Dyas appealed again. The appellate court vacated the trial court’s denial of Dyas’s motion to withdraw his guilty plea, citing non-compliance with Rule 401(a) regarding the waiver of counsel for postplea proceedings, and remanded for new postplea proceedings.The appellate court, Third District, vacated the trial court’s denial of Dyas’s motion to withdraw his guilty plea, finding that the trial court failed to comply with Rule 401(a) when accepting Dyas’s waiver of counsel for postplea proceedings. The appellate court remanded the case for new postplea proceedings.The Supreme Court of Illinois reviewed the case and found that the appellate court lacked jurisdiction over Dyas’s appeal because his notice of appeal was filed more than 30 days after the denial of his Rule 604(d) postjudgment motion. The court held that a successive postjudgment motion to reconsider the denial of a motion to withdraw a guilty plea does not toll the time for filing a notice of appeal. Consequently, the appellate court’s judgment was void. The Supreme Court vacated the appellate court’s decision and affirmed the circuit court’s judgment. View "People v. Dyas" on Justia Law
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Criminal Law, Supreme Court of Illinois
People v. Harris
Ralph Harris was convicted in three separate cases involving murder, attempted robbery, and aggravated criminal sexual assault. He filed an omnibus motion to suppress his confessions, alleging they were obtained through physical and mental coercion by detectives. The circuit court denied the motion, finding the confessions were voluntary. Harris was convicted, and his convictions were affirmed on direct appeal.Harris then filed postconviction petitions under the Post-Conviction Hearing Act, alleging newly discovered evidence of a pattern of police torture corroborated his claims of coerced confessions. The circuit court advanced the petitions to a third-stage evidentiary hearing but ultimately denied relief, finding the new evidence did not prove his confessions were coerced. Harris appealed, and the appellate court reversed, remanding for a new suppression hearing to consider the new evidence.On remand, a new judge conducted the suppression hearing and denied Harris's coercion claim but vacated his convictions and ordered new trials, citing the potential impact of the new evidence on a jury. The State appealed, arguing the appellate court had jurisdiction to review the circuit court's order. Harris moved to dismiss the appeal, claiming it was an unauthorized interlocutory appeal.The Illinois Supreme Court reviewed the case and held that the appellate court had jurisdiction to consider the State’s appeal. The court found that the appellate court in Harris I had not vacated Harris’s convictions or ordered new trials but had remanded for a new suppression hearing. The proceedings on remand were a continuation of the postconviction proceedings, resulting in a final order from which the State could appeal. The court reversed the appellate court's dismissal and remanded for consideration of the State's appeal. View "People v. Harris" on Justia Law
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Criminal Law, Supreme Court of Illinois
People v. Yankaway
Jatterius L. Yankaway was arrested on April 7, 2020, for allegedly shooting Robert Hunter on July 26, 2019. Due to the COVID-19 pandemic, the Illinois Supreme Court had tolled speedy-trial terms in criminal proceedings. On September 19, 2022, a jury found Yankaway guilty of attempted first-degree murder, aggravated battery, and unlawful possession of a weapon by a felon (UPWF). The Peoria County circuit court sentenced him to consecutive prison terms for attempted murder and aggravated battery but reserved sentencing on the UPWF conviction.On appeal, Yankaway argued ineffective assistance of counsel for failing to file a speedy-trial demand under the intrastate detainers statute, that his convictions violated the one-act, one-crime rule, and that the circuit court misapprehended the minimum sentence for attempted first-degree murder. The appellate court affirmed in part, finding no ineffective assistance as Yankaway could not show prejudice, and no plain error in sentencing. However, it vacated the aggravated battery conviction under the one-act, one-crime rule and remanded for sentencing on the UPWF conviction.The Illinois Supreme Court reviewed the case. It affirmed the appellate court's judgment regarding counsel's effectiveness but on different grounds, and it affirmed the sentencing for Yankaway’s convictions. The court found that the intrastate detainers statute did not apply to Yankaway as he was not committed to the Department of Corrections when the State proceeded on one of his charges. The court also found that defense counsel performed deficiently by failing to object to a continuance but held that this did not prejudice Yankaway as the continuance was attributable to him. The court concluded that the circuit court did not abuse its discretion in attributing the continuance to Yankaway and denying his motion to dismiss. Finally, the court found no plain error in the sentencing decision. The part of the appellate court judgment remanding for sentencing on the UPWF conviction was vacated. View "People v. Yankaway" on Justia Law
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Criminal Law, Supreme Court of Illinois
People v. Guy
Travaris T. Guy was convicted of attempted first degree murder and second degree murder for the shooting of David Woods Sr. and Sheena Woods. The jury found that Guy acted with the intent to kill but also believed his actions were lawfully justified, which led to an inconsistent verdict. Guy did not raise this issue on direct appeal or in his initial postconviction petition but later filed a successive postconviction petition claiming inconsistent verdicts and ineffective assistance of counsel.The Will County circuit court denied relief on the inconsistent verdict claim but granted a new trial on a separate claim. The appellate court reversed Guy’s attempted first degree murder conviction, holding that the jury instruction misstated the law, the conviction was inconsistent with the second degree murder conviction, and the jury’s finding of self-defense precluded a guilty verdict for attempted first degree murder.The Illinois Supreme Court reviewed the case and affirmed the appellate court’s judgment in part, reversed in part, and remanded to the circuit court to sentence Guy on the lesser-included offense of aggravated battery with a firearm. The court held that a conviction for attempted first degree murder requires proof of intent to kill without lawful justification. The jury instruction was erroneous as it only required intent to kill. The jury’s finding that Guy believed in the need for self-defense was incompatible with the intent required for attempted first degree murder. The court also found that Guy’s attorneys were ineffective for failing to properly raise these issues. View "People v. Guy" on Justia Law
People v. Williams
Michael Williams pled guilty to two counts of aggravated battery with a firearm and was sentenced to two consecutive 10-year terms. Williams later filed a postconviction petition alleging ineffective assistance of counsel, claiming his trial counsel allowed the trial judge's son to participate in a pre-plea meeting. The circuit court dismissed the petition at the second stage of postconviction proceedings.The appellate court reversed the circuit court's dismissal, finding that Williams's postconviction counsel provided unreasonable assistance by failing to adequately support the claim of ineffective assistance of trial counsel. The appellate court remanded the case for further second-stage proceedings with new counsel.The Illinois Supreme Court reviewed the case and reversed the appellate court's decision. The Supreme Court held that Williams's postconviction counsel did not provide unreasonable assistance. The court noted that the postconviction petition survived the first stage and was not found deficient or frivolous by the trial court. The Supreme Court found no evidence in the record to suggest that additional facts or arguments could have been included in the petition to support Williams's claim. The court concluded that the arguments made by postconviction counsel were the best options available under the circumstances, even if they were ultimately unsuccessful. The Supreme Court affirmed the circuit court's judgment dismissing Williams's postconviction petition. View "People v. Williams" on Justia Law
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Criminal Law, Supreme Court of Illinois
People v. Morgan
The defendant, Kendall Cecil Morgan, was charged with home invasion and domestic battery for allegedly entering Vanessa Williams' apartment without authority and striking her in the face. The State filed a petition to deny Morgan pretrial release, citing the charges and arguing that his release posed a threat to the community. At the detention hearing, the State presented evidence of the charges and Morgan's criminal history, including a previous conviction for armed robbery and pending cases for DUI and battery. The defense argued that Morgan had been diagnosed with bipolar disorder and suggested conditions like electronic monitoring and mental health treatment.The McLean County Circuit Court found that the State had established by clear and convincing evidence that Morgan committed the offenses, posed a threat to the community, and that no conditions could mitigate his dangerousness. The court granted the State's petition to deny pretrial release. Morgan appealed, arguing that the State had not met its burden and that the appellate court should review the circuit court's decision de novo.The Illinois Appellate Court reviewed the circuit court's decision for an abuse of discretion and upheld the denial of pretrial release. The appellate court reasoned that the circuit court's ability to observe the defendant warranted deference, even when the evidence was presented by proffer.The Illinois Supreme Court reviewed the case to determine the appropriate standard of review for pretrial detention decisions under section 110-6.1 of the Code of Criminal Procedure. The court held that when live testimony is presented, the circuit court's decision should be reviewed under the manifest weight of the evidence standard. However, when the parties proceed solely by proffer, the reviewing court should conduct a de novo review. Applying de novo review, the Supreme Court affirmed the circuit court's judgment denying Morgan pretrial release. View "People v. Morgan" on Justia Law
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Criminal Law, Supreme Court of Illinois