Justia Criminal Law Opinion Summaries

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

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

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

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

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

The defendant was convicted of unlawful possession of a controlled substance after a stipulated bench trial. The conviction stemmed from evidence found in a locked kitchen cabinet during a warrantless search by police officers who were investigating a gas leak in the defendant's home. The defendant filed a motion to suppress the evidence, arguing that the search was unreasonable and violated the Fourth Amendment. The trial court denied the motion, and the defendant was subsequently convicted.The Second District Appellate Court affirmed the conviction, holding that the police officers' actions were permissible under the community caretaking or emergency aid exceptions to the warrant requirement. The appellate court found that the use of a flashlight to look into the cabinet did not constitute a search under the Fourth Amendment. One justice dissented, arguing that the use of the flashlight to peer into a locked cabinet was a search in violation of the Fourth Amendment.The Supreme Court of Illinois reviewed the case and reversed the lower courts' judgments. The court held that the contraband found in the locked cabinet was not in plain view and that the police officers' actions constituted an unreasonable search. The court concluded that the use of a flashlight to look into the cabinet, which was secured with a chain and padlock, amounted to a search that was not justified by the emergency aid or community caretaking exceptions. As a result, the trial court erred in denying the defendant's motion to suppress the evidence. The Supreme Court reversed the defendant's conviction and vacated his sentence. View "People v. Hagestedt" on Justia Law

The case involves the transition from a pretrial system with monetary bail to one without it, as per amendments to the Illinois Code of Criminal Procedure. Damarco Watkins-Romaine, charged with multiple serious offenses, was ordered released pending trial with a $350,000 bail, which he could not pay. After the amendments abolishing monetary bail took effect, he petitioned for release, arguing that the financial condition was improper. The State responded with a petition to detain him under the new Code.The Cook County circuit court denied Watkins-Romaine's petition for release. The appellate court reversed this decision, holding that the legislature did not intend to allow the State to file a petition for pretrial detention under these circumstances and that the State's petition was untimely.The Illinois Supreme Court reviewed the case and reversed the appellate court's decision. The Supreme Court held that the State may file a petition to detain a defendant pretrial in response to a defendant’s petition to remove the condition of monetary bail, even if the defendant had been ordered released but could not satisfy the previously set monetary bail. The court found that the procedures followed in the circuit court were fair and consistent with the amended Code. The case was remanded to the appellate court to consider Watkins-Romaine's remaining contentions. View "People v. Watkins-Romaine" on Justia Law

In 1999, Sedrick White, then 20 years old, entered a blind guilty plea to one count of first-degree murder and was sentenced to 40 years in prison by the Cook County circuit court. Over 20 years later, White filed a pro se petition for postjudgment relief under section 2-1401(f) of the Code of Civil Procedure, arguing that his 40-year sentence constituted a de facto life sentence in violation of the Eighth Amendment of the U.S. Constitution and the proportionate penalties clause of the Illinois Constitution. The circuit court denied the petition, stating that the sentence did not violate the Eighth Amendment or the proportionate penalties clause.White appealed the circuit court's decision, arguing that his 40-year sentence violated the proportionate penalties clause. The appellate court affirmed the circuit court's decision, holding that White's guilty plea waived any potential constitutional claim regarding his sentence. The appellate court also found that the circuit court did not err in failing to recharacterize White's section 2-1401 petition as a petition under the Post-Conviction Hearing Act.The Supreme Court of Illinois reviewed the case and agreed with the parties that White's blind guilty plea did not waive his constitutional challenge to his sentence. The court clarified that a defendant who enters a blind guilty plea, with no agreement as to the sentence, does not waive the right to challenge the sentence. However, the court found that White's 40-year sentence was not a de facto life sentence and was not "wholly disproportionate to the offense as to shock the moral sense of the community." The court concluded that White failed to state a meritorious claim that his sentence violated the proportionate penalties clause and affirmed the judgments of the appellate court and the circuit court. View "People v. White" on Justia Law

On June 17, 2016, Olvan Quezada was involved in a series of events at the Briarwood Apartments in Waukegan, Illinois, which led to his arrest. Police responded to a domestic disturbance call and later heard gunshots. Quezada was found with a gun under the couch where he had been sleeping. Witnesses and police officers testified about the events, including the gunshots directed at officers and Quezada's actions. Quezada was identified by witnesses and through police investigation.The Circuit Court of Lake County convicted Quezada of attempted murder of a police officer, aggravated discharge of a firearm, unlawful possession of a firearm by a street gang member, and possession of a defaced firearm. He was sentenced to concurrent prison terms for these offenses. Quezada appealed, arguing insufficient evidence for the gang-related firearm possession charge and citing trial errors, including the admission of interrogation videos and gang evidence.The Appellate Court reversed Quezada's conviction for unlawful possession of a firearm by a street gang member due to insufficient evidence. It also reversed his remaining convictions, citing the cumulative effect of two unpreserved trial errors: the admission of the interrogation videos and gang evidence. The court found these errors collectively denied Quezada a fair trial.The Supreme Court of Illinois reviewed the case and affirmed the appellate court's decision to reverse the gang-related firearm possession conviction. However, it reversed the appellate court's decision regarding the remaining convictions. The Supreme Court held that the cumulative error doctrine could not be applied to unpreserved errors unless they collectively amounted to plain error. Since Quezada's trial counsel had acquiesced to the admission of the interrogation videos, he was estopped from challenging them as plain error. The remaining gang evidence error alone did not justify reversal. Thus, Quezada's convictions for attempted murder, aggravated discharge of a firearm, and possession of a defaced firearm were reinstated. View "People v. Quezada" on Justia Law

The defendant, Angelo Clark, was charged with multiple counts of attempted first-degree murder and aggravated battery following a gang-related shooting in 2013 that injured two people. Clark moved to quash his arrest, which was based on an investigative alert issued by the Chicago Police Department. The circuit court denied his motion, and Clark did not contest this denial further in the circuit court.In 2017, a jury in the Cook County Circuit Court convicted Clark of two counts of aggravated battery with a firearm under an accountability theory. He was initially sentenced to 46 years in prison, which was later reduced to 32 years upon reconsideration.Clark appealed, and the Appellate Court, First District, affirmed his conviction and sentence. The appellate court rejected Clark's argument that his arrest was unconstitutional because it was based on an investigative alert rather than a warrant. The court also found no plain error in the circuit court's consideration of sentencing factors for juvenile offenders, as Clark was 17 at the time of the offense.The Supreme Court of Illinois reviewed the case and affirmed the appellate court's judgment. The court held that warrantless arrests based on probable cause do not violate the Illinois Constitution, even if communicated via an investigative alert. The court also found that the circuit court had considered the relevant factors for sentencing juvenile offenders, as required by section 5-4.5-105(a) of the Unified Code of Corrections, and thus, there was no clear or obvious error in the sentencing process. View "People v. Clark" on Justia Law