Justia Criminal Law Opinion Summaries

Trenton Jefferson was tried for first degree murder in the circuit court of St. Clair County. The jury found him guilty but answered negatively to a special interrogatory asking if the State had proven beyond a reasonable doubt that Jefferson personally discharged a firearm causing the victim’s death. The appellate court reversed Jefferson’s conviction for unrelated reasons and ordered a new trial. Jefferson then argued that the jury’s answer to the special interrogatory, under the doctrine of issue preclusion as embodied in the double jeopardy clause of the federal constitution, barred the State from arguing or presenting evidence in his retrial that he personally discharged a firearm causing the victim’s death. The trial court granted the motion, but the appellate court reversed the judgment, holding that the jury’s answer to the special interrogatory did not bar the State from arguing or presenting evidence that Jefferson discharged the firearm.The Supreme Court of the State of Illinois affirmed the judgment of the appellate court. The court concluded that the jury’s answer to the special interrogatory and general verdict could be understood as an indication that the jury was unable to determine whether Jefferson or another individual shot the victim, but that it had determined, beyond a reasonable doubt, that either one or the other did. Because a rational jury could have grounded its verdict upon an issue other than that which Jefferson sought to foreclose from consideration, Jefferson failed to establish that the doctrine of issue preclusion applied. Therefore, the trial court erred in granting Jefferson’s motion to suppress evidence. The State, on retrial, is not barred from again arguing that either Jefferson or the other individual shot the victim. However, the State is barred from seeking a sentence enhancement on remand, as the State conceded that Jefferson cannot get the enhancement ever again. View "People v. Jefferson" on Justia Law

The case involves Antuan Joiner, who was convicted of first-degree murder and two counts of attempted murder following a 2014 bench trial in the circuit court of Cook County. The appellate court affirmed his convictions, remanded for a new sentencing hearing, and affirmed the new sentence imposed on remand. Joiner subsequently filed a petition for postconviction relief under the Post-Conviction Hearing Act, which the circuit court summarily dismissed as frivolous and patently without merit. Joiner appealed, arguing that the petition must be advanced to the second stage both because the circuit court failed to rule on it within 90 days after it was filed and docketed and because the claims had merit. The appellate court affirmed the circuit court’s judgment.The Supreme Court of the State of Illinois affirmed the judgment of the appellate court. The court held that the trial court complied with the Act and dismissed Joiner's petition within 90 days after it was filed and docketed on August 4, 2021. The court also found that Joiner was not arguably prejudiced by counsel’s failure to call certain witnesses. Based on the strength of the victims’ identification of Joiner as the shooter, the court concluded that the proposed testimony by the witnesses would not have arguably changed the outcome of the trial. View "People v. Joiner" on Justia Law

The case involves Char M. Shunick, who was convicted of unlawful possession of a controlled substance with intent to deliver and unlawful possession of a controlled substance. After his conviction, Shunick filed a petition for postconviction relief, which was summarily dismissed by the circuit court of Knox County. Shunick then filed a motion to reconsider the dismissal, which was also denied by the circuit court. The appellate court found that Shunick's motion to reconsider was untimely and, as a result, his notice of appeal was also untimely. Consequently, the appellate court concluded that it lacked jurisdiction to address the substantive merits of the appeal.The Supreme Court of the State of Illinois affirmed the judgment of the appellate court. The court found that Shunick's motion to reconsider was not timely filed under the Illinois mailbox rule, rendering his subsequent notice of appeal untimely and preventing appellate court jurisdiction over the substantive merits of his appeal. The court also found that the appellate court did not have jurisdiction to order a remand to allow Shunick to cure the jurisdictional defect by supplying a compliant certificate of service. The court concluded that the appellate court correctly followed precedent and concluded that it lacked jurisdiction to remand the cause to allow Shunick to cure the jurisdictional defect by supplementing the record with a compliant certificate of service. View "People v. Shunick" on Justia Law

The defendant, Korem M. Johanson, was found guilty of Class X felony predatory criminal sexual assault of a child following a bench trial in the circuit court of McHenry County. Before sentencing, Johanson argued that the penalty for this offense violated the proportionate penalties clause of the Illinois Constitution, as it contained identical elements to the less severe Class 2 felony offense of aggravated criminal sexual abuse but carried a harsher sentence. The circuit court denied this motion and sentenced Johanson to 16 years' imprisonment.Johanson appealed, maintaining the same argument. The appellate court affirmed the circuit court's decision, concluding that the two offenses did not contain identical elements. While both offenses required the victim to be under the age of 13, the court found that the definition of sexual conduct for the offense of aggravated criminal sexual abuse could be satisfied without contact involving the sex organ or anus, which was a requirement for the offense of predatory criminal sexual assault of a child.The Supreme Court of the State of Illinois affirmed the lower courts' decisions. The court found a clear difference between the two offenses based on the statutory language. While acts that satisfy the contact element of predatory criminal sexual assault of a child also satisfy the element of sexual conduct, the opposite is not always true. Therefore, the two offenses do not contain identical elements. The court also rejected Johanson's argument that the elements of the offense as alleged in this case were identical for both offenses, stating that this was an as-applied challenge, which is not appropriate under the identical elements test. The court concluded that the more severe sentence provided for the offense of predatory criminal sexual assault of a child is not constitutionally disproportionate to the less severe sentence for the offense of aggravated criminal sexual abuse. View "People v. Johanson" on Justia Law

The Supreme Court of the State of Illinois reviewed a case where a defendant, Ramon Torres, was convicted of predatory criminal sexual assault of his four-year-old daughter. The State’s evidence included testimony that Torres tested positive for chlamydia in 2013 and again in 2016. On appeal, Torres argued that his trial counsel was constitutionally ineffective for failing to object to the admission of evidence of these two test results. He maintained that the test results fell under the purview of the physician-patient privilege statute and that none of the statutory exceptions to the physician-patient privilege applied.This case required the court to interpret the physician-patient privilege statute and whether the test results would have been excluded from evidence at his jury trial had his attorney objected. The appellate court disagreed with Torres and affirmed his conviction and sentence. The Supreme Court of the State of Illinois affirmed the lower courts’ judgments.The court held that the physician-patient privilege statute did not apply to the 2016 test results as Torres submitted to testing in 2016 not for the purpose of seeking medical treatment, but because he was ordered to do so by the Department of Children and Family Services. Therefore, the privilege and the exceptions to the privilege were irrelevant to the admissibility of the 2016 test results.Regarding the 2013 test results, the court found that the physician-patient privilege statute does apply. The court, however, determined that the exception set out in subsection (7) authorizes physicians to disclose information subject to the physician-patient privilege “in actions, civil or criminal, arising from the filing of a report in compliance with the Abused and Neglected Child Reporting Act.” Therefore, the 2013 chlamydia test results were admissible even though the physician-patient privilege attached to those test results. The court concluded that the defendant has not satisfied the first prong of the Strickland standard, and his claim of ineffective assistance of counsel fails. View "People v. Torres" on Justia Law

The Supreme Court of the State of Illinois considered an appeal by Emanuel Wells, who had entered a fully negotiated plea agreement with the state. Wells had pleaded guilty to one count of unlawful possession of cannabis with the intent to deliver and received the minimum six-year sentence. He also agreed to pay a $100,000 fine and was credited for the 54 days he had spent in custody. After sentencing, Wells filed a motion to receive credit for time he spent on home detention prior to the plea. The trial and appellate courts denied the motion, holding that a fully negotiated guilty plea constitutes a waiver of presentence custody credit not provided for in the plea agreement.The Supreme Court of the State of Illinois affirmed the lower courts' decisions. It held that a fully negotiated plea deal that is a complete and final expression of the parties' agreement gives rise to a presumption that every material right and obligation is included and that neither party may unilaterally seek modification of the agreement. The court found that Wells, by entering into a plea deal that granted him 54 days of credit, agreed to forgo his right to credit for time he spent on home detention. Although it was unclear whether Wells was aware of the potential credit for his time spent on home detention, the court determined that Wells waived this right by entering into a plea agreement that provided for 54 days of credit. Consequently, Wells was not entitled to additional credit not included in the agreement. View "People v. Wells" on Justia Law

The Supreme Court of the State of Illinois evaluated a case involving Jessica Logan, who was convicted of first-degree murder for the death of her 19-month-old son. Before her trial, Logan moved to suppress a video reenactment of her son’s death, arguing that police should have given her Miranda warnings. The trial court denied the motion to suppress and the video was admitted as evidence. The appellate court affirmed the trial court's judgment, finding that the reenactment was not custodial.The Supreme Court of Illinois affirmed the judgment of the appellate court, but for different reasons. The court found that Logan was in custody during the reenactment and should have received Miranda warnings. Despite this, the court held that admitting the reenactment as evidence did not amount to plain error, as the evidence of Logan's guilt was not closely balanced. The court also rejected Logan's claims that her trial counsel rendered ineffective assistance, finding that she had not shown a reasonable probability that the outcome of the trial would have been different if her counsel had acted differently. View "People v. Logan" on Justia Law

In this case, the defendant, Clayton T. Marcum, was convicted of two counts of aggravated domestic battery and sentenced to consecutive prison terms of seven years on each count. Marcum appealed, arguing that his right to a speedy trial had been violated, he did not knowingly waive his right to counsel, the State failed to prove him guilty of aggravated domestic battery, and the circuit court violated his right to remain silent when it ordered him to participate in the preparation of his presentence investigation report.The appellate court agreed that the evidence was insufficient to prove Marcum guilty of aggravated domestic battery. As a result, his convictions were reduced to Class 3 aggravated batteries and the case was remanded to the trial court for resentencing. The appellate court rejected Marcum's remaining arguments. The defendant appealed to the Supreme Court of the State of Illinois, only contesting his speedy trial and waiver of counsel claim.The Supreme Court of the State of Illinois affirmed the judgment of the appellate court. The court held that a violation of the statutory right to a speedy trial does not alone constitute plain error. The court also found that the trial court substantially complied with Rule 401(a) in admonishing Marcum, therefore he effectively waived his right to counsel at trial and continuing through sentencing. The case was remanded to the trial court for further proceedings consistent with the appellate court’s order remanding the case to the trial court for resentencing on the reduced convictions for aggravated battery. View "People v. Marcum" on Justia Law

This case concerns a challenge to an Illinois statute that prohibits child sex offenders from living within 500 feet of a day care home. The plaintiff, Martin Kopf, who in 2003 had pleaded guilty to aggravated criminal sexual abuse involving a 15-year-old victim, argued that the statute was unconstitutional. The Supreme Court of Illinois determined that the statute did not violate Kopf's substantive due process and equal protection rights, as it was rationally related to the legitimate state interest of protecting children. The court noted that while the law may create difficulties for sex offenders in finding compliant housing, it does not force them to leave their communities. The court reversed the lower court's decision that found the statute facially unconstitutional and remanded the case for further proceedings on the plaintiff's as-applied challenges. View "Kopf v. Kelly" on Justia Law

In 2011, Shamar Griffin entered a guilty plea in the circuit court of Cook County, Illinois, to one count of first-degree murder in exchange for a 35-year sentence and the dismissal of additional charges. Several years later, Griffin filed a motion to file a successive post-conviction petition, alleging actual innocence and ineffective assistance of counsel. The circuit court denied the motion, finding that Griffin's guilty plea precluded his actual innocence claim. The appellate court reversed, allowing Griffin to file a petition alleging actual innocence despite his guilty plea.The Supreme Court of Illinois held that the same standard applies to all petitioners when determining whether to grant leave to file a successive post-conviction petition based on an actual innocence claim, regardless of whether the petitioner was convicted following a trial or pleaded guilty. The court also held that each claim in a successive post-conviction petition must meet the applicable standard in order to advance to second-stage post-conviction proceedings.In this case, the court found that Griffin presented a colorable claim of actual innocence based on newly discovered evidence that, if true, could lead to his acquittal on retrial. This evidence included two affidavits identifying a different individual as the actual shooter. The court affirmed the appellate court's decision allowing Griffin to file a successive post-conviction petition based on his actual innocence claim, but it remanded the case to the appellate court for further consideration of Griffin's claim of ineffective assistance of counsel. View "People v. Griffin" on Justia Law