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People v. Clemons
Illinois Supreme Court · 2012-04-19 · cited 14×
In this case, defendant Corey Clemons was convicted of armed robbery and home invasion while armed with a firearm, each carrying a Class X felony sentence enhanced by 15 years for firearm use, resulting in a 21-to-45-year range. The Illinois Supreme Court considered whether to overrule its prior decision in People v. Hauschild, which had found the armed robbery firearm enhancement unconstitutional under the proportionate penalties clause because it imposed a harsher penalty than the identical offense of armed violence, or to abandon the identical elements test used in such analyses. The court affirmed the validity of Hauschild and declined to abandon the test, relying on stare decisis and finding no special justification for departure. It therefore upheld the appellate court's remand for resentencing on the armed robbery conviction under the pre-enhancement statute with a 6-to-30-year range.
criminal law
Wilson v. County of Cook
Illinois Supreme Court · 2012-04-05 · cited 107×
This case challenged the constitutionality of Cook County's Blair Holt Assault Weapons Ban ordinance prohibiting possession of certain assault weapons defined by model names or technical characteristics. Plaintiffs sought a declaration that the ordinance violated due process, equal protection, and the Second Amendment right to bear arms. The Illinois Supreme Court affirmed dismissal of the due process and equal protection claims, finding the ordinance was neither unconstitutionally vague nor arbitrary in its classifications of weapons. It reversed dismissal of the Second Amendment claim, holding that plaintiffs had sufficiently pleaded a cause of action warranting further proceedings in the trial court.
gunscivil rights
People v. Baskerville
Illinois Supreme Court · 2012-02-17 · cited 32×
The case involved Joseph Baskerville, who was charged with obstructing a peace officer under Illinois law after he gave a deputy false information about his wife's whereabouts during an investigation of her driving on a suspended license. The Illinois Supreme Court addressed whether the obstruction statute requires proof of a physical act and whether knowingly providing false statements can qualify as obstruction. The court held that a physical act is not necessary and that false statements may constitute obstruction when they impede an officer's authorized duties, but concluded that the State failed to prove the statements here actually hindered the officer's performance of the traffic stop. Accordingly, the court affirmed the appellate court's reversal of the conviction.
criminal law
People v. Rinehart
Illinois Supreme Court · 2012-01-20 · cited 21×
The case involved defendant Thomas Rinehart's 2007 conviction for criminal sexual assault against a 17-year-old with developmental disabilities, resulting in a 28-year prison sentence. The Illinois Supreme Court affirmed the conviction and sentence but vacated the appellate court's remand order, holding that the statute requires an indeterminate mandatory supervised release term of three years to natural life rather than a determinate term chosen by the trial court within that range. The court reasoned that the legislature deliberately established this indeterminate MSR structure for sex offenses to address recidivism risks, as evidenced by related statutes providing for ongoing supervision and discharge reviews, in contrast to the determinate sentencing framework for other crimes. The court also rejected the defendant's challenge to the State's voir dire questions about delayed reporting by sexual assault victims.
criminal law
People v. Villa
Illinois Supreme Court · 2011-12-01 · cited 6×
The case involved defendant Victor Villa, who was convicted by a jury of aggravated battery with a firearm and aggravated discharge of a firearm based on a drive-by shooting in Boone County, Illinois, under an accountability theory. The Illinois Supreme Court addressed whether the trial court erred by allowing the State to impeach Villa's testimony with his prior juvenile adjudication for burglary. The court held that Illinois law generally prohibits using juvenile adjudications to impeach a testifying defendant, that Villa's testimony did not open the door to such evidence by misleading the jury about his criminal history, and that the erroneous admission was not harmless. It therefore reversed the convictions and remanded for a new trial. The ruling turned on interpretation of the Juvenile Court Act's restrictions on the use of delinquency findings.
criminal lawprocedure
People v. Grayer
Illinois Supreme Court · 2011-09-28
This case involved a petition for leave to appeal from an Illinois appellate court ruling in a criminal prosecution of Anthony Grayer. The Illinois Supreme Court denied the petition but invoked its supervisory authority to direct the Appellate Court, First District, to vacate its decision in People v. Grayer and reconsider the matter. The reconsideration is to be conducted in light of the Illinois Supreme Court's intervening decision in People v. Mullins to determine whether a different result is required. Justice Theis took no part in the order.
criminal lawprocedure