State Supreme Court Data Tracker

Summary of Case Context & HoldingOhio voters approved a constitutional amendment that created a tax-exempt bond fund for making grants to political subdivisions and nonprofit organizations to revitalize and preserve natural spaces. The fund is administered by the Ohio Public Works Commission (OPWC). The village of Barnesville applied for two grants to fund the purchase land for "open space" projects. The village entered into an agreement with the OPWC that restricted the use of the land. The village subsequently transferred the oil and gas rights of the land to a corporation without the OPWC's consent. The Supreme Court found that the oil and gas lease violated the restrictions of the agreement between the village and the OPWC and that the use restriction was enforceable and did not violate public policy.

Summary of Case Context & HoldingThe Supreme Court considered whether an error pursuant to Hurst v. Florida, 577 U.S. 92 (2016) (requiring that a jury find each fact necessary to impose a sentence of death) can be harmless if the jury’s recommended sentence of death is eleven to one. During an attempted robbery, four witnesses were set to testify against Okafor. Okafor then returned to the home of the witnesses with a gun, and one of the witnesses was killed. Okafor was convicted by a jury of one count of first-degree premeditated murder, two counts of attempted first-degree murder, and one count of armed burglary of a dwelling with explosives or a dangerous weapon. On appeal, Okafor argued that the trial court erred in striking Juror 105 for cause based on his allegedly equivocal responses to whether he would be able to impose the death penalty after determining it was the appropriate punishment. The Supreme Court noted that a juror is only unqualified if they express an unyielding rigidity toward the death penalty. However, in this case, Juror 105 had claimed that even if instructed to assume that the death penalty was appropriate, he was unsure that he could vote to recommend it. Thus, the trial court did not err in dismissing Juror 105 for cause. Lastly, Okafor claims that because the recommendation of death was not unanimous, his sentence is unconstitutional under Hurst. The Supreme Court reasoned that because the jury did not unanimously find the facts necessary to impose death and did not render a final unanimous verdict to recommend the death penalty, it must vacate Okafor's death sentence and remand for a new penalty phase.

Summary of Case Context & HoldingAt trial, the jury heard evidence of two prior incidents in which Defendant had assaulted other women. The prosecution offered this evidence to show criminal intent and the trial court admitted it under Rule 404(b), O.C.G.A. § 24-4-404 (b), which states that "evidence of other crimes, wrongs, or acts shall not be admissible to prove the character of a person in order to show action in conformity therewith. It may, however, be admissible for other purposes, including, but not limited to, proof of motive, opportunity, intent, preparation, plan, knowledge, identity, or absence of mistake or accident." Defendant appealed. The Supreme Court vacated the Defendant's appeal and clarified its holding in Bradshaw, including that Defendant's not guilty plea put the prosecution to its burden of proving every element of the crime, including intent, and making evidence of other acts showing intent relevant. See Bradshaw v. State, 769 S.E.2d 892 (Ga. 2015). The Supreme Court noted that its discussion of intent in Bradshaw may have confused the lower courts by overstating the value of such evidence when offered to prove intent. The Supreme Court clarified that Bradshaw's suggestion that the burden of proving intent always is an especially difficult burden for the prosecution and that evidence of other acts that tend in any way to prove intent ordinarily will be admissible for that purpose was more applicable to conspiracy cases specifically, where it is particularly difficult to prove intent. The probative value of evidence and the extent to which evidence tends to make the existence of a fact more or less probable depends significantly on the quality of the evidence and the strength of its logical connection to the fact for which it is offered. An accurate assessment of probative value is an essential part of a proper application of Rule 403, which embodies the second requirement for the admission of evidence of other acts under Rule 404(b).

Summary of Case Context & HoldingDefendant was convicted of DUI less safe and failure to maintain a lane, among other crimes. Defendant appealed, challenging the denial of his motion to suppress the results of a state-administered breath test on the grounds that the implied consent notice statute, O.C.G.A. § 40-5-67.1(b), was unconstitutional on its face and as applied to him. Defendant argued: (1) that his right against compelled self-incrimination was implicated when law enforcement asked him to expel deep lung air into a breathalyzer; (2) that the materially misleading language of the implied consent notice was coercive per se and in fact did compel him to perform this act; and (3) the admission of his breath test results violated his right against compelled self-incrimination under the Georgia Constitution and his due process rights. The Supreme Court held that under the compelled self-incrimination clause of the Georgia Constitution, individuals have the right to refuse to take a breathalyzer test, and it overruled prior decisions that held otherwise. However, the Supreme Court rejected defendant’s facial challenges to the implied consent notice statute, because the language of that notice was not per se coercive.

Summary of Case Context & HoldingA corporation appealed the City of Green Bay's decision to rescind a conditional use permit for a renewable energy facility on the basis that the permit was obtained through misrepresentation. Initially, the corporation presented extensive evidence of the facility's design and emission status, and approvals from the City's Division of Safety and Buildings and the U.S. Department of Energy. Based on these presentations and discussions with the company, the city council approved the permit. Then, members of the public complained about construction to the city council based on references in the building permit to "stacks" and "emissions." It was after the complaints from the public that the council voted to rescind the permit. The Supreme Court held that there was no evidence that the company made intentional misrepresentations about its emissions, smokestacks, or technology, and that the decision to rescind the permit was not based on substantial evidence. The stacks referenced in the permit were not smokestacks, as the public believed them to be, and all emissions from the facility were determined to be environmentally compliant, as originally presented by the corporation.

Summary of Case Context & HoldingPlaintiff Lela Operton was denied unemployment benefits by the Labor and Industry Review Commission on the basis that she was terminated for substantial fault when she made eight inadvertent errors over the course of 80,000 cash-handling transactions. She appealed this decision. The Supreme Court held that inadvertent errors are not the type of disqualifying substantial fault that would prevent an employee from receiving unemployment benefits. In this present case, Operton's errors were inadvertent and exempt from the statutory definition of substantial fault under Wis. Stat. § 108.04(5g).

Summary of Case Context & HoldingThe Governor requested an advisory opinion as to her obligation under the Alabama Constitution to issue a writ of elections to fill a vacancy in either house of the legislature. Under the circumstances at issue, a representative died with only nine months remaining on their term. By the time the special election would occur the winner would only serve for four to five months. The Governor sought an advisory opinion on three questions (1) Does the Governor bear any duty under the constitution's legislative-vacancy provision before receiving formal notice of a legislator's death from the appropriate probate judge? See Ala. Const. [1901], § 46; Ala. Code [1975,] § 36–9–6; (2) Does the constitution's legislative-vacancy provision impose on the Governor an absolute duty to call a special election whenever a vacancy occurs regardless of how much time remains in the term of office? See Ala. Const. [1901,] § 46; and (3) If a special election must be called to fill a legislative vacancy only when practicable, will this Court defer to the Governor's reasonable judgment about the practicability of calling any particular special election? See Ala. Const. [1901,] § 46. The Justices of the Alabama Supreme Court were of the opinion as to the first question, that the state constitution directs the Governor to issue a writ of election whenever a vacancy occurs in either house of the legislature, not merely upon receipt of notice from the probate court of a legislator's death. The Justices found that Section 46(b) discusses the duty of the Governor “whenever a vacancy occurs” and contains no qualifying language as to the form or source of notice of that vacancy. As to the second question, the Justices of the Alabama Supreme Court were of the opinion that the state constitution's provision on filling vacancies in the legislature does require the Governor to issue a writ of election. The Justices reached the conclusion based on the use of the mandatory language in the Constitution that the governor "shall" issue a writ of election. The Justices declined to answer the third question, because it was a hypothetical question assuming an answer to the second question different from the answer given.

Summary of Case Context & HoldingThe Orange County Board of Commissioners proposed, and voters approved, an amendment to the county charter imposing term limits on a variety of positions (e.g., comptroller, sheriff, supervisor of elections) and requiring nonpartisan elections for those positions. Three of the county’s officers sued, and the lower courts held that the imposition of term limits was permissible, but the provision mandating nonpartisan elections was barred because it was preempted by Florida's statewide Election Code. The Florida Supreme Court affirmed, concluding that the Florida Election Code generally contemplated partisan elections, and county constitutional officers were not among its exceptions. The amendment was also preempted because: (1) it required the election of county officers during primary elections, while the Election Code required them to appear on the general election ballot; and (2) it prohibited officers from seeking party nomination, which was expressly permitted by the Election Code. Of note, this decision superseded a prior majority's opinion in the case, which reached the opposite conclusion, based on a change in the composition of the Court.

Summary of Case Context & HoldingPetitioner Rober Osbey was charged with two counts of drug possession and trafficking. Petitioner pled guilty almost a year after his arrest, without counsel. The plea court found that Petitioner had knowingly waived his right to counsel by conduct as he had been informed by a court official on three separate occasions that he would have to submit an application to have a public defender appointed, but did not for nearly a year. Petitioner then filed a post-conviction relief application on the grounds that he did not knowingly and voluntarily waive his right to counsel. The Court overruled State v. Roberson, 675 S.E.2d 732 (S.C. 2009), holding that any waiver of counsel, even one by conduct, must be "knowingly and intelligently," which requires that a defendant be made aware of the dangers and disadvantages of self-representation. Consequently, the Court held that the Petitioner did not waive his right to counsel by his conduct because he was not made aware of the dangers of self-representation.

Summary of Case Context & HoldingSection 15-86(c) of the Property Tax Code provides that a hospital applicant “shall be issued” a charitable property tax exemption if the value of certain qualifying services or activities provided by the hospital in a given year equals or exceeds the hospital's estimated property tax liability for the same year. 35 ILCS 200/15-86(c) (Section 15-86(c)). Plaintiff's complaint alleged that because Section 15-86(c) commands that the hospital applicant receive the charity property tax exemption if the statutory criteria are satisfied, it was facially unconstitutional because it mandates the tax exemption without considering whether the subject property is used exclusively for charitable purposes as required under Section 6 of Article IX of the Illinois Constitution. The Supreme Court read "shall be issued" as permissive rather than mandatory, favoring an interpretation under which the statute would be considered constitutional. Therefore, hospitals seeking a Section 15-86 charitable property tax exemption will be required to document services and activities meeting the statutory criteria and show exclusive charitable use. Moreover, the Plaintiff's challenge failed because she brought a facial challenge to the statute meaning that under no set of circumstances the statute would be valid. However, Plaintiff conceded it could be possible that a hospital applicant could satisfy both Section 15-86(c) requirements and exclusive charitable use under Section 6 of Article IX. Accordingly, the Supreme Court held that Plaintiff failed to establish facial invalidity and affirmed the judgment of the appellate court.

Summary of Case Context & HoldingIn 1992, Appellant was found guilty of two counts of first-degree murder and two counts of attempted first-degree murder at age 15, after being certified to adult court. The district court imposed two mandatory life sentences with the possibility of release and two 15-year sentences. In 1994, Appellant directly appealed his sentences and they were affirmed. In 2015, Appellant moved to correct his sentences because the junior court failed to follow the correct adult certification procedures before referring him to adult court, because (i) he waived the jurisdiction of the juvenile court (which is not permitted); (ii) the waiver was involuntary and unintelligent; (iii) he did not receive sufficient notice of the charges before certification; (iv) the prosecution made insufficient filings; and (v) the juvenile court failed to make sufficient findings of fact. On appeal, the appeals court denied relief without a hearing, having construed Appellant's filing as a petition, rather than a motion under Rule 27.03, because it implicated more than just Appellant's sentence. The Supreme Court agreed that the filing implicated more than just the sentence, and that as a result the construal as a petition was correct. Under State v. Knaffla, 243 N.W.2d 737 (1976), a petition is untimely two years after all claims known at the time of a direct appeal, or that should have been known at that time. Because all allegedly defective procedures related to Appellant's conviction were known at the time of the direct appeal in 1999, the Minnesota Supreme Court affirmed as the petition was untimely.

Summary of Case Context & HoldingThe Supreme Court considered whether it is unconstitutional for the State of Georgia to maintain the confidentiality of the names and other identifying information of the persons and entities involved in executions, including those who manufacture the drug or drugs to be used. The trial court concluded that the access to identity and due process was denied based on the execution-participant confidentiality statute, O.C.G.A. § 42-5-36(d). The Supreme Court reversed the trial court and dissolved the injunction that prohibited the inmate's execution with a drug produced by undisclosed persons and entities. The Supreme Court held that although there has been a tradition of allowing at least some public access to execution proceedings, there has also been a long-standing tradition of concealing the identities of those who carry out those executions. The Supreme Court found that without the confidentiality offered to execution participants by the statute, there was a significant risk that persons and entities necessary to the execution would become unwilling to participate. The Supreme Court concluded that Georgia's execution process is likely made more timely and orderly by the execution-participant confidentiality statute and, furthermore, that significant personal interests are also protected by it.

Summary of Case Context & HoldingPlaintiff, a worker at the One World Trade Center construction site, sustained injuries when he slipped and fell while descending an exterior metal staircase (also referred to as a temporary scaffold) that was wet from exposure to the elements. The issue on appeal was whether the Appellate Division properly determined that Plaintiff was entitled to summary judgment on liability on his Labor Law § 240(1) cause of action. Under Labor Law § 240(1), owners and contractors engaged “in the erection, demolition, repairing, altering, painting, cleaning or pointing of a building or structure,” except certain owners of one- and two-family dwellings, must “furnish or erect ... scaffolding, hoists, stays, ladders, slings, hangers, blocks, pulleys, braces, irons, ropes, and other devices which shall be so constructed, placed and operated as to give proper protection to a person” employed in the performance of such labor. Finding that there were triable issues of fact as to whether the staircase provided sufficient protection, the Court of Appeals held that summary judgment should not have been granted in Plaintiff’s favor on the issue of liability. In particular, there were conflicting expert opinions as to the adequacy of the staircase as a safety device. The Court of Appeals also reiterated that the mere fact that Plaintiff fell did not, in itself, establish a violation of Labor Law § 240(1).

Summary of Case Context & HoldingFulton County’s former Chief Financial Officer and Interim County Manager, Patrick J. O’Connor, sued Fulton County (County) for firing him after the County Board of Commissioners (Board) formally voted to end O’Connor’s tenure as Interim County Manager and to replace O’Connor as Chief Financial Officer, effective immediately, although the County’s attorney later informed O’Connor that the Board would allow him to resign from the Finance Director position in lieu of termination. O’Connor argued that the Fulton County Personnel Regulations (which set forth the policies applicable to Fulton County employees) constitute an employment contract and that under Regulation 300-4 (7), he was entitled to be returned to his former position as Finance Director after he was removed as Interim County Manager. He also argued that once he was reinstated to his former position, he could only be terminated by the County Manager, not by the Board. During his employment, he was an unclassified, at-will employee. Among other issues, the Supreme Court analyzed whether the Fulton County Personnel Regulations amount to an enforceable employment contract. Answering this question in the negative, the Supreme Court found that, generally speaking, the policies and information in personnel or employee manuals neither create a contract nor support a claim for breach of contract. Specifically, the Supreme Court further noted that Regulation 300-4 (7) controls the administration of certain temporary appointments and does not amount to a promise of future compensation; accordingly, the provision does not form the basis of an employment contract. Additionally, even if the County failed to follow its own procedures under Regulation 300-4 (7) when it terminated his employment, such a claim, even if true, does not give rise to a claim for breach of contract.

Summary of Case Context & HoldingDeath-row inmates brought action against the state and the Ohio Department of Rehabilitation and Correction (ODRC) seeking declaratory and injunctive relief to determine and enforce their right not to be subjected to ODRC's execution protocol, arguing that ODRC's execution protocol was an invalid process because it was not adopted by following the procedures for promulgating an administrative rule. The Supreme Court ruled that the ODRC's written lethal-execution protocol amounted to nothing more than an instruction manual governing ODRC employees regarding the infrequent occurrence of a lethal-injection execution—and was not, therefore, a "rule" subject to formal rule-making that would require filing with the Secretary of State, the Legislative Service Commission, and the Joint Committee on Agency Rule Review.

Summary of Case Context & HoldingThe Pennsylvania Democratic Party sued the Secretary of the Commonwealth and county Election Boards to establish drop boxes, accept ballots mailed by Election Day but received up to one week after the election, provide voters with meaningful notice and opportunity to cure deficient mail-in ballots, accept “naked” ballots (mail-in ballots returned without an outer secrecy envelope), and uphold the residency requirement for poll-watchers. The Supreme Court found that state election law authorized the use of drop boxes, provided for a three-day extension to ballots received after election day, and upheld the residency requirement for poll-watchers. The Supreme Court, however, rejected the plaintiff's claim for a meaningful opportunity to cure incorrectly submitted ballots. Additionally, the Supreme Court rejected the acceptance of "naked" ballots, finding that the legislature intended the requirement for a outer secrecy envelope to be mandatory. The U.S. Supreme Court subsequently denied an emergency appeal by the Trump campaign which claimed the Pennsylvania Supreme Court’s three-day extension of the ballot receipt deadline was unconstitutional.

Summary of Case Context & HoldingEnvironmental organization challenged constitutionality of budget-related decisions leading to oil and gas lease sales under Pennsylvania Constitution's Environmental Rights Amendment. The Supreme Court reversed in part and vacated in part the commonwealth court's decision, concluding that the Commonwealth of Pennsylvania, as trustee of Pennsylvania's environmental trust (including state parks and forests and oil and as minerals therein), must manage it according to the Environmental Rights Amendment, which imposes fiduciary duties. Further, the Commonwealth was restricted by the Amendment in how it disposed of proceeds generated from sale of public natural resources, such that the proceeds must be returned to the environmental public trust.

Summary of Case Context & HoldingOn remand, the commonwealth court granted the Commonwealth of Pennsylvania summary relief that revenues generated from oil and gas leases on state forest and game lands were not part of state's environmental trust. Environmental organization appealed, challenging diversion of income from environmental public trust to General Fund. The Supreme Court concluded that revenue from oil and gas leases on public environmental land was income generated from assets of natural resources trust and that the income could not be diverted from environmental trust to General Fund for non-trust purposes without violating Environmental Rights Amendment of Pennsylvania Constitution. See also Pa Env't Defense Found. v. Commonwealth, 161 A.3d 911 (Pa. 2017).

Summary of Case Context & HoldingPlaintiff Paradis, a teacher, sued Defendants (high school, county school district, principal, and assistant principal) for defamation and civil conspiracy. Plaintiff alleged that her desire to report a student's misconduct to the police led to her being targeting for an unwarranted and invasive performance evaluation, blacklisted, ostracized, and eventually terminated from her teaching position. The South Carolina Supreme Court certified the question of whether a plaintiff must plead special damages as an element of a civil conspiracy claim. The Court clarified that contrary to the apparent requirements of its prior opinion in Todd v. South Carolina Farm Bureau Mutual Insurance Co., 278 S.E.2d 607 (S.C. 1981), a plaintiff asserting a civil conspiracy claim need not plead special damages, but rather (1) the combination or agreement of two or more persons; (2) to commit an unlawful act or a lawful act by unlawful means; (3) together with the commission of an overt act in furtherance of the agreement; and (4) damages proximately resulting to the plaintiff.

Summary of Case Context & HoldingDefendant was convicted of child molestation and nine counts of sexual exploitation of a minor and was sentenced to 12 years in prison. Upon his release from custody, Defendant was classified as a “sexually dangerous predator” under O.C.G.A. § 42-1-14 (a) (1), which designation required Defendant to wear and pay for an electronic monitoring system for the remainder of his life. The Supreme Court found that the permanent application of a monitoring device and the collection of data by the State about an individual's whereabouts twenty-four hours a day, seven days a week, through warrantless GPS monitoring for the rest of that individual's life, even after that person has served the entirety of his or her criminal sentence, constitutes a significant intrusion upon the privacy of the individual being monitored. The Supreme Court stated that individuals who have completed their sentences do not have a diminished expectation of privacy that would render their search by a GPS monitoring device reasonable. The Supreme Court found such searches to be patently unreasonable, and concluded that O.C.G.A. § 42-1-14(e) is unconstitutional on its face to the extent that it authorizes such searches of individuals who are no longer serving any part of their sentences in order to find evidence of possible criminal conduct.

Summary of Case Context & HoldingAn employee alleged that her prior employer terminated her employment in retaliation for her workers' compensation claim related to an injury that she suffered while at work. The employee was fired on July 3, 2014, and filed her complaint alleging wrongful termination on March 21, 2018. The employer moved to dismiss the complaint, arguing that the two-year statute of limitations under NRS 11.190(4)(e) applied because wrongful termination is an action in tort and that the limitations period had therefore expired. The district court agreed that the employee's claims were time-barred and granted the motion to dismiss. The issue presented to the Supreme Court was whether dismissal based on the two-year statute of limitations period in NRS 11.190(4)(e) was warranted here. The Supreme Court reasoned that because the statute does not set forth an express limitations period for wrongful termination, it is appropriate to consider analogous causes of action for which express limitations periods are available. Here, the Supreme Court found wrongful termination analogous to "damages for injuries to a person or for the death of a person caused by the wrongful act or neglect of another" under NRS 11.190(4)(e) (which has a two-year statute of limitations), because both claims involve injury to an ex-employee's personal rights caused by the wrongful act of another. The court rejected the argument that the "catch-all" provision in the statute provided a four-year limitations period for wrongful termination claims, because the catch-all provision does not apply where there is an analogous cause of action with an express statute of limitations. Accordingly, the Plaintiff's case was time-barred and properly dismissed because the claims for wrongful termination are subject to the two-year limitations period prescribed by NRS 11.190(4)(e) for injuries or death caused by another person's wrongful act or neglect.

Summary of Case Context & HoldingThis case concerns the extent to which the court can direct medical treatment for a child. Here, a mother desired to socially transition her male child to become a female, without the father's knowledge or consent. The father moved for sole custody, which the court granted. The court also implemented mandatory guidelines, many of which followed a doctor's recommendation as to the care of the child. The father appealed the mandatory guidelines on the basis that they unconstitutionally infringed on his right to make decisions concerning his child, and the court of appeals vacated certain of the mandatory guidelines, including the choice of therapist, judicial immunity for the therapist, and a gag-order on discussing certain topics with the child. The Supreme Court of Arizona affirmed the court of appeals ruling determining that the mother failed to show that the father's exercise of sole legal decision-making authority would place the child at risk of physical injury or significantly impair the child's emotional development. The Court also vacated the family court's orders to the extent they granted authority to a counselor and doctor and limited the father's sole legal decision-making authority.

Summary of Case Context & HoldingThe case involved a dispute between the Pennsylvania Department of Transportation (PennDOT) and coal companies over whether PennDOT deprived the coal companies of their use of a coal estate in such a way that constituted an illegal taking. The coal companies argued that when PennDOT cut off their access to a particular part of land, it resulted in the loss of coal, which could be considered a taking. The Supreme Court held that no taking occurred and remanded the case for consideration of the coal companies' consequential damages claim.

Summary of Case Context & HoldingIn March 2012, Ginger Thompson brought her daughter, A.W., to Pediatrics Cool Care, a pediatric clinic that A.W. had been a patient at for multiple years. A.W. reported symptoms of constant sadness and an inability to control her feelings. A.W. was subsequently diagnosed by a physician assistant with depression and was prescribed Celexa, an anti-depressant. The physician assistant could not recall whether she warned Thompson and A.W. that Celexa could cause suicidal ideation, but later testified that it was common practice to do so. Although the assistant only intended to prescribe a 30-day supply of Celexa, the medical assistant transcribing the record mistakenly indicated that A.W. was to receive three 30-day refills. Five months later, Thompson called the clinic and sought to have the prescription refilled. A medical assistant took the call and approved the refill without authorization from the lead doctor or any other providers in the clinic. Two weeks later, A.W. committed suicide. Neither of her parents had been aware that A.W. had any suicidal thoughts. A.W.’s parents (Plaintiffs) sued the clinic, the presiding doctor, and certain care providers for negligence and gross negligence. At trial, the jury heard testimony from multiple experts who detailed the failures in the treatment provided by the clinic. The jury returned a verdict in favor of A.W.’s parents, holding both the doctor in charge of the clinic and the physician assistant who initially attended to A.W. and prescribed Celexa liable. The jury rendered a multimillion dollar verdict that was reduced by the trial court to $1.285 million. On appeal, the court held that the expert testimony provided was sufficient evidence to support the negligence claim. Notably, while medical malpractice claims generally require consideration of both “but-for” causation (meaning that the harm experienced by the patient would not have occurred “but for” the actions of the care provider) and “substantial factor” causation (where a court considers whether the actions of the care provider were a “substantial factor” in the harm experienced by the patient), the court of appeals did not consider but-for causation, and limited its review to substantial factor analysis. The care providers then appealed to the Supreme Court, requesting review only as to the failure of the court of appeals to consider “but-for” causation in its analysis. The Court held that the court of appeals had erred in not considering but-for causation and that but-for analysis was required in medical malpractice cases, unless multiple defendants’ actions were so concurrent to make it impossible to examine them in isolation. The Court reviewed the evidence presented, including the expert testimony examining the deficiencies of the practices of each of the care providers, and held that there was insufficient evidence to support finding that alternative actions could have prevented a suicide that the Court viewed as potentially “spontaneous, impulsive—and thus, unpreventable.” Because the Supreme Court could not find any evidence that the actions of care providers were the "but-for" cause of A.W.'s death, the Court reversed the court of appeals and entered judgment for the Defendants. Justice Boyd wrote a dissenting opinion, joined by Justice Lehrmann, noting that it was the role of the jurors to consider the testimony of the expert witnesses and that a reasonable juror could have found but-for causation here.

Summary of Case Context & HoldingPetitioner Linda Pedroza sought review of her second-degree murder conviction and sentencing for a crime she committed as a juvenile. The Court considered whether Pedroza's forty-year sentence for second-degree murder, which she received in exchange for a plea deal, is unconstitutional under the Eighth Amendment to the U.S. Constitution as interpreted and applied in Miller v. Alabama, 567 U.S. 460 (2012). The Court granted review due to the many certified conflicts among the Florida districts. Ultimately, the Florida Supreme Court upheld the sentence and found that it was not unconstitutional. Pedroza’s arguments hinged upon reasoning from Miller and Graham v. Florida, 560 U.S. 48 (2010). Graham is a U.S. Supreme Court decision which held that a sentence of life imprisonment without the possibility of parole for a juvenile offender is unconstitutional under the Eighth Amendment. The Graham court intended that all juvenile offenders receive some meaningful opportunity to obtain release based on demonstrated maturity and rehabilitation. In Miller, the U.S Supreme Court determined that juvenile sentences must take into account the uniqueness of juvenile defendants prior to imposing a sentence of life without parole. The opinions in Graham and Miller were later interpreted in Henry v. State, 175 So. 3d 675 (Fla. 2015) to apply not only to sentences for “life” but also to sentences that ensure imprisonment throughout a juvenile offender's natural life. Here, the Court found that, although the trial court failed to take into consideration Pedroza’s juvenile status when considering her sentence, her sentence is not unconstitutional under Miller because it is not a sentence of life imprisonment. The Court was not convinced that the reasoning in Henry was applicable here, because Pedroza’s sentence was not effectively a life imprisonment as her sentence was only forty years in contrast to the ninety year sentence in Henry. Importantly, the Court also addressed the apparant conflicts between its opinion and the holidings in Florida districts due to the stretching of dicta in Kelsey v. State, 206 So. 3d 5, 10-11 (Fla. 2016) and Johnson v. State, 215 So. 3d 1237, 1243 (Fla. 2017). In particular, the Court clarified that the holding of Kelsey did not mean, as applied by other districts, that all juvenile sentences longer than twenty years are unconstitutional. Rather, the Court in Kelsey explicitly stated that it was only determining the narrow issue of how to apply the reasoning in Henry to juveniles whose life sentences had been vacated pursuant to Graham, but who had not been resentenced under the new juvenile sentencing guidelines. In considering Johnson, the Court determined that a juvenile offender's sentence does not implicate Graham and therefore Miller, unless it meets the threshold requirement of being a life sentence or the functional equivalent of a life sentence. In a dissent opinion, Justice Labarga argued that Pedroza's situation was disproportionately harsh, noting that a life sentence for first-degree murder would have entitled her to resentencing under Miller. Despite the dissent, the Court upheld Pedroza's sentence because she did not establish that it is a life sentence or the functional equivalent of a life sentence.

Summary of Case Context & HoldingHolloway worked at Oakridge Convalescent Home—a nursing home managed by Oakridge Nursing & Rehabilitation Center LLC (Oakridge Rehab). In February 2011, Holloway filed a charge against the nursing home and Oakridge Rehab claiming discrimination on the basis of age and disability in violation of the Illinois Human Rights Act. In January 2012, Oakridge Rehab negotiated with its landlord, Oakridge Rehab Properties, to transfer its assets to a new entity that would take over the facility, Oakridge Healthcare, LLC. The transfer agreement between Oakridge Rehab and Oakridge Healthcare detailed that Oakridge Healthcare was not liable nor subject to any judgment against Oakridge Rehab. In September 2012, the Illinois Department of Human Rights conducted an investigation and filed a civil rights complaint on Holloway's behalf, seeking relief against Oakridge Rehab. In September 2013, an administrative judge ruled in Holloway’s favor, but Oakridge Rehab had already dissolved and was unable to pay the Commission's judgment awarding Holloway with $30,880 and back pay. The State filed a civil complaint against both Oakridge Rehab and Oakridge Healthcare for fraud. The Supreme Court found no evidence that Oakridge Healthcare intended to defraud creditors, including Holloway, by acquiring Oakridge Rehab's assets. The Court acknowledged Oakridge Rehab's dire financial situation, emphasizing its inability to meet even basic obligations like rent, let alone its debt to Holloway. Since Illinois follows the common law rule that a corporation which purchases another corporation is not subject to debts or obligations incurred by the corporation that previously operated the business, the judgment entered against Oakridge Rehab did not apply to Oakridge Healthcare, and Holloway's judgment was not paid.

Summary of Case Context & HoldingThe Illinois Attorney General sued J.T. Einoder, Inc. and Tri-State Industries for operating a waste disposal site without proper permits under the Illinois Environmental Protection Act (IEPA). The circuit court, the lowest level state court in Illinois, held that the Defendants had engaged in open dumping and received construction and demolition debris without a permit and issued a mandatory injunction to move and safely dispose of the open waste. In addition, monetary damages were imposed against the companies and the individual company heads, specifically, Janice Einoder. The Defendants appealed the ruling, including the imposed damages, to the Illinois Supreme Court. The Illinois Supreme Court held that the mandatory injunction was improper because the IEPA only allowed prohibitory injunctions at the time the waste site was operational, which was from 1993-2003. In 2004, the IEPA was amended to allow all forms of injunctive relief, including mandatory injunctions, but the Illinois Supreme Court found that only a clear statement from the legislature, which was not present in this case, allowed for an amendment to be enforced retroactively. Therefore, the mandatory injunction was vacated. The Defendants would have to cease their illegal action, but the Court could not order them to rectify and remove their illegally dumped waste. In addition, the Illinois Supreme Court affirmed that Janice Einoder could accrue monetary damages. The Illinois Supreme Court held that corporate officers could be found liable under the IEPA and the jury’s findings should be given deference. Therefore, despite evidence that Janice Einoder was not involved in the day-to-day operations of the site, the Court found that her involvement with the business still made her liable.

Summary of Case Context & HoldingDefendant Jorge Guzman was charged with aggravated possession of stolen firearms. During his plea hearing, the court did not admonish Guzman with respect to the potential impact of pleading guilty on his immigration status pursuant to Section 113-8 of the Code of Criminal Procedure. Guzman entered into a fully negotiated guilty plea, and a month later, filed a written motion to withdraw his plea and argued he was not admonished pursuant to Section 113-8. The trial court denied his motion to withdraw the plea, and the appellate court reversed his conviction. However, the Supreme Court affirmed the trial court's denial of his motion to withdraw the guilty plea, concluding that the failure to admonish did not affect the voluntariness of the plea. The Court rejected Guzman's argument that the U.S. Supreme Court’s decision in Padilla v. Kentucky, 559 U.S. 356 (2010) warranted an overruling of the Illinois Supreme Court’s prior decision in Illinois v. Delvillar, 922 N.E.2d 330 (Ill. 2009). Delvillar determined that admonishments are not mandatory under section 113-8, and thus whether the failure to admonish is unconstitutional will depend on other factors such as the voluntariness of the plea. Guzman argued that the reasoning in Padilla, which held that counsel must inform the client of the risk of deportation associated with a guilty plea, indicated that a plea is unconstitutionally involuntary in the absence of a statutory admonishment regarding the immigration consequences of a guilty plea. However, the Court explained that Padilla states no such rule explicitly or even implicitly. Rather, there are several logical leaps to reach Guzman's conclusion. Accordingly, the Court determined that Padilla does not mandate a holding that the failure to give a Section 113–8 admonishment entitles a defendant to withdraw their guilty plea. As a result, the Court declined to overrule Delvillar based on Padilla.

Summary of Case Context & HoldingDefendant Jose Valdez was charged with burglary for taking jewelry from an unoccupied house. At his pretrial hearing, the parties informed the court that Valdez would plead guilty to burglary. The court admonished Valdez in accordance with Illinois Supreme Court Rule 402(a) and, pursuant to Section 113-8 of the Code of Criminal Procedure, explaining that a burglary conviction “may have the consequences of deportation, exclusion from admission to the United States, or denial of naturalization.” Valdez said he understood and still wished to plead guilty. Later, the judge again admonished Valdez that pleading guilty meant he could be deported, and Valdez again acknowledged that he understood. The court accepted the guilty plea. Within 30 days, Valdez filed a pro se motion to “open and vacate” his conviction, and circuit court-appointed new counsel filed an amended motion alleging that defense counsel failed to inform Valdez of the consequences of his guilty plea on his resident alien status. The court denied the motions, and the appellate court vacated. However, the Illinois Supreme Court reversed, reinstating the denial of the motion. The Supreme Court found that any prejudice (a requirement for relief as a result of counsel's deficient performance) was cured by the court’s own admonishments.

Summary of Case Context & HoldingDefendant was convicted of first degree murder. At a hearing, Chicago police officer Banito Lugo testified that he and his partner were dispatched to a building because of a report of a battery in progress. The officers spoke to Defendant, who said everything was alright, and to Defendant’s neighbor, who had made the call to police, and who was "adamant" about what he had heard and maintained that someone upstairs was injured. The officers left and came back because “something didn’t feel right.” On return they saw an open back gate, entered the open rear door of Defendant’s apartment, and searched room to room after receiving no response, upon which they found the murder victim laying on a mattress. Defendant argued on appeal that the appellate court erred by relying on the emergency aid exception to the warrant requirement, in part because a lapse of 15 to 20 minutes between the officers' arrival on the scene and their entry into the apartment was not consistent with an emergency situation. The Supreme Court held that in Illinois, a two-part test is used to determine whether the emergency aid exception applies—reasonable grounds to believe an emergency exists and probable cause. Here, the totality of the circumstances (the conversations with the Defendant and downstairs neighbor, the open gates and door to the apartment, and the officers' investigation during the elapsed time) at the time of entry provided an objective, reasonable basis for the police to believe that someone was injured inside the apartment. The Supreme Court further held that probable cause was also established when the officers reasonably believed someone was in danger.

Summary of Case Context & HoldingIn 1996, Defendant was convicted with a series of crimes. At sentencing, Defendant refused to apologize to the deceased victim's family and laughed, so the Court of Appeals ultimately imposed an aggregate term of more than 66 years to life in prison. On appeal in 2000, the appellate counsel specifically argued that, at the time of Defendant's arrest, the police conducted an illegal search, but the Appellate Division affirmed the judgment of conviction. In 2017, Defendant commenced this proceeding claiming that the appellate counsel's performance was constitutionally defective because he allegedly failed to communicate with Defendant during the pendency of his direct appeal, submitted an appellate brief that was poorly structured and that did not challenge the length of the minimum portion of the indeterminate sentence imposed as unduly harsh and severe in the interest of justice, and neglected to file a criminal leave application seeking leave to appeal to this Court. The Appellate Division denied Defendant's application. The Court of Appeals decided that the intermediate appellate court correctly determined that the quality of counsel's appellate brief did not constitute ineffective assistance because, while the brief could have been better drafted, the brief demonstrated appellate counsel's grasp of the relevant facts and law, and the intermediate appellate court addressed each of the four reviewable issues raised by appellate counsel; thus, the intermediate appellate court properly denied Defendant's petition for a writ of error coram nobis.

Summary of Case Context & HoldingIn October 2014, the Defendant verbally threatened his then-girlfriend (Victim) via phone call and text message. He stated that he had a gun and would come to the apartment and kill her. Victim then went to her mother’s house and called the police. A responding officer met with the Victim and took screenshots of her cellphone while the Defendant continued texting threatening messages. Another officer found the Defendant in a vehicle near the Victim’s residence and took him into custody. The Victim testified at trial that the Defendant’s communications caused her to fear for her life. The State charged the Defendant with two counts of felony stalking based on conduct that he knew or should have known would cause a reasonable person (1) to fear for her safety (Count I); and (2) to suffer emotional distress (Count II). The trial court found Defendant guilty on Count II and sentenced him to 1.5 years’ imprisonment and 4 years’ mandatory supervised release. The Defendant argued on appeal that subsection (a) of the relevant statute violated state and federal constitutional guarantees of (1) due process (no mens rea requirement and impermissibly vague); and (2) free speech (overbroad criminalization of protected speech). The appellate court acknowledged that the Supreme Court in People v. Relerford, 104 N.E.3d 341 (Ill. 2017), had found that subsection (a) was overbroad and violated the right to free speech. But the appeals court sustained Defendant’s conviction because his conduct otherwise violated the statute. While conflicting precedent regarding whether the statute required an objective or subjective standard concerning a “true threat,” the appeals court determined that it need not resolve this conflict because the Defendant’s statements constituted a threat either way. At the Supreme Court, the Defendant argued that the stalking statute is facially unconstitutional by violating his federal right to free speech and the right to substantive due process by criminalizing innocent conduct. The Supreme Court first analyzed the legislative history and intent of the stalking statute. Amendments thereto were intended to prohibit the use of newer technologies in a stalking behavior in patterns that statistically lead to homicide. This analysis focused on the word “threatens” as used in the statute, which the Supreme Court interpreted as referring to only a “true threat.” To arrive at that conclusion, the Supreme Court examined U.S. Supreme Court precedent regarding the First Amendment overbreadth doctrine. Such law allows a defendant to challenge a statute on First Amendment grounds when even his own conduct did not give him standing in order to prevent the “chilling” effect on speech that a statute could have. The U.S. Supreme Court had found that this doctrine excepted certain categories of speech such as true threats. The Illinois Supreme Court analyzed the term “threatens” in the context of the entire statute, the legislative intent as expressed through the legislative history, and other principles of statutory construction. Because the legislature intended the term “threatens” to refer to “true threats” of violence, the stalking statute only criminalized unprotected speech. Next, the Illinois Supreme Court addressed whether the stalking statute failed to specify a mens rea requirement for a true threat. The issue was whether the Defendant intended to communicate a threat or reasonably should have known that his statements would be perceived as threatening. The statute’s language “means to communicate” requires a conscious awareness “of the threatening nature of” speech, which only requires subjective awareness via “an intentional or knowing mental state.” The Illinois Supreme Court therefore upheld the “means to communicate” phrase. However, because the statute’s “should know” language only required criminal negligence, the mens rea was unconstitutional. On these same grounds, the Illinois Supreme Court determined that the statute was adequately tailored to prevent stalking victims from actual harm or the threat of harm. The Defendant next argued that the stalking statute is facially unconstitutional under the substantive due process clause of the Fourteenth Amendment. First, the Illinois Supreme Court determined that the statute did not criminalize otherwise innocent conduct because the “threatens” provision encompasses speech only “intentionally or knowingly convey[ing] true threats of unlawful violence.” Second, the Illinois Supreme Court rejected the argument that the statute is impermissibly vague for the same reason—the statute provides fair warning of prohibited conduct. Next, the Illinois Supreme Court determined that the statute was narrowly tailored to the legislative intent by requiring that the victim experience only emotional harm and not necessarily fear of bodily harm or death. Finally, the Defendant lacked standing to challenge the statute on substantive due process grounds because, unlike with the First Amendment, there is no “overbreadth” doctrine applicable in this context that would allow him to challenge the statute using hypothetical examples. The Illinois Supreme Court also upheld the sufficiency of the evidence used to convict the Defendant.

Summary of Case Context & HoldingDefendant, who only spoke Spanish, was arrested and charged with a Driving While Intoxicated but was not given a Physical Coordination Test (three tests consisting of: walk and turn, the one-leg stand and finger to nose) during the arrest, as is NYPD policy for non-English speakers. Defendant argued this policy violated his equal protection and due process rights under both State and Federal Constitutions. For the Equal Protection claim, the court of appeals held that the NYPD policy survives rational basis review as the public has an interest in ensuring the results from these lengthy and ubiquitous tests are neither unreliable nor administratively overburdensome (as would be the case if tests required translators). For the Due Process claim, the court of appeals held that Defendants do not have a constitutional due process right to Physical Coordination Tests or other discretionary investigative techniques.

Summary of Case Context & HoldingIn 1996, Defendant was convicted on several drug charges and accepted a plea deal which rendered him subject to deportation, a consequence of which he was unaware. Defendant later moved to vacate his conviction, arguing that, per the U.S. Supreme Court's 2010 ruling Padilla v Kentucky, 559 U.S. 356 (2010), his counsel's failure to advise him on the immigration consequences of his plea deal made his counsel ineffective. The Court of Appeals held that while Padilla does require the court to include advice about the immigration consequences of a guilty plea, it barred this requirement from being applied to cases made before the Padilla ruling.

Summary of Case Context & HoldingDefendant pleaded guilty in 1993 to second-degree criminal sexual conduct. Two years later, while he was serving a prison sentence, Michigan’s Sex Offender Registration Act (SORA) took effect. After completing parole, Defendant failed to register his change of residence and was charged with violating SORA’s registration requirements. The Supreme Court held that the retroactive application of SORA violated state and federal constitutional prohibitions on ex post facto laws.

Summary of Case Context & HoldingDefendant was convicted of first-degree murder following a jury trial arising from a shooting. During an interview with police officers prior to the trial, Defendant confessed to the shooting in a handwritten statement. However, Defendant moved to suppress the statement, alleging that it was the result of physical coercion by two detectives. The trial court denied the motion to suppress, and Defendant was subsequently found guilty. Defendant filed a second successive postconviction petition alleging that new evidence showed the detectives exhibited a pattern of misconduct. He attached an unnotarized affidavit to the petition outlining the alleged abuse, as well as complaints alleging other instances of physical and verbal abuse by the officers. The trial court denied the petition. The appellate court affirmed, finding that subsequent evidence of police misconduct was irrelevant because Defendant had relied on personal knowledge to form the basis of the petition and that personal knowledge had been available to him at the time of the trial. The Supreme Court rejected this holding, but affirmed the decision irrespective of the error. In rejecting the holding, the Supreme Court stated that the appellate court had adopted a rule that strayed from the majority of other appellate court decisions (e.g., People v. Brandon, 195 N.E.3d 284 (Ill. 2021) and would lead to absurd results, as even conclusive evidence that a confession was coerced, presented to a postconviction court immediately upon its discovery would not be able to amount to cause. As such, the Supreme Court considered the appellate court’s holding to be contrary to legislative intent. The Supreme Court affirmed the decision, however, because it found that Defendant had failed to establish prejudice by showing that the failure to raise the claim during the initial proceeding caused the resulting conviction to violate due process. Specifically, Defendant testified at trial that he made the statement “merely to appease” the officers who would not accept his story, but in the petition he changed his story and said the officers physically coerced him. Because the allegations in the petition were “directly contradicted by his sworn trial testimony,” Defendant failed to show prejudice and the successive petition was correctly denied.

Summary of Case Context & HoldingDefendant, an African-American man, was charged for robbery after being identified by two white victims as the man who had robbed them, in the absence of any physical evidence. The trial court denied the Defendant’s request to instruct the jury that there is a near scientific tenet that people have more difficulty identifying members of different races than they do identifying members of their own race. The Court of Appeals held that when identification is an issue in a criminal case and witnesses and the defendant are of different races, defendants are entitled to instruct the jury on this cross-race effect.

Summary of Case Context & HoldingThe Supreme Court ruled that judges must consider youth as a mitigating factor in sentencing, even when life in prison without parole is not being sought. Under two laws passed in the wake of the U.S. Supreme Court decision in Miller v. Alabama, 567 US 460 (2012) (mandating consideration of youth for juvenile defendants facing potential life in prison without possibility of parole sentencing) juvenile defendants who are convicted of certain enumerated acts may receive a minimum sentence of 25 to 40 years and a maximum sentence of 60 years. The Supreme Court found that to both (1) avoid the state constitution’s ban on cruel or unusual punishment; and (2) fulfill the mandated need for proportionality—age must be considered as a mitigating factor given the wide range of potential sentences.

Summary of Case Context & HoldingIn trial court, Defendant was convicted upon a jury verdict of murder in the second degree, multiple counts of criminal contempt, and offering a false instrument for filing. He was sentenced to a term of imprisonment of 23 years to life. Nine years after he was sentenced, Defendant moved pro se to vacate his convictions under CPL § 440.10, arguing that he was improperly forced to wear a stun belt throughout his trial. It is undisputed that sheriff officials required Defendant to wear a stun belt at trial, that neither the State nor the trial court were aware of that fact, and that Defendant failed to preserve any argument concerning the stun belt. Because the trial court did not articulate a particularized need for Defendant to wear a stun belt, the use of that restraint was error. However, this flaw was not a mode of proceedings error (see People v Buchanan, 912 N.E.2d 553 (N.Y. 2009)). The courts thus did not abuse their discretion by summarily denying the portion of Defendant's CPL §440.10 motion based on his unpreserved assertion of a Buchanan error, which could have been raised before the trial court.

Summary of Case Context & Holding"Batson challenges" are challenges to a prosecutor's decisions to exclude a member of the jury pool by analyzing whether these exclusions are discriminatory (e.g., striking only one race or gender from the jury pool). In this case, Defendant was a dark-colored Black male charged with robbery. During jury selection, Defendant's counsel lodged a Batson challenge after the prosecutor excluded five dark-skinned women (four Black women and one Indian-American woman), a challenge which was rejected on the grounds that skin color was not a cognizable class for which a challenge can be lodged. Siding with the Defendant, the Court of Appeals held that skin color, is, indeed, a cognizable class under the State constitution, for which a Batson challenge can be lodged.

Summary of Case Context & HoldingDefendant filed a pro se postconviction petition alleging that his 50-year prison sentence for first-degree murder, imposed in 2008 for discharging a firearm when he was a juvenile, was unconstitutional as applied to him under the Eighth Amendment. Specifically, Defendant alleged that the sentencing court failed to consider his youth and its attendant characteristics under Miller v. Alabama, 567 U.S. 460 (2012), which was decided while Defendant’s direct appeal was pending. The Supreme Court noted that it had previously held in People v. Davis, 6 N.E.3d 709 (Ill. 2014) that Miller applied retroactively to cases on collateral review. The Supreme Court held that, in determining whether a juvenile defendant’s prison term is long enough to be considered de facto life without parole, the line should be drawn at 40 years in light of a legislative determination by the Illinois General Assembly. Accordingly, the Supreme Court vacated Defendant’s 50-year sentence as unconstitutional under the Eighth Amendment and remanded for a new sentencing hearing.

Summary of Case Context & HoldingDefendant was charged with unlawful possession with intent to deliver after officers searched her home pursuant to a warrant. Officers based the warrant on Defendant's prior arrest for marijuana possession, images of marijuana found on Defendant's social media, and the officer's use of a drug-detection dog to sniff Defendant's apartment door. Defendant moved to suppress the evidence, arguing that the warrantless drug-detection dog sniff violated her Fourth Amendment rights pursuant to the U.S. Supreme Court's decision in Florida v. Jardines, 569 U.S. 1 (2013), which held that a drug-detection dog sniff of the curtilage of a home constitutes a search under the Fourth Amendment. The appellate court agreed, and found that the warrantless search of Defendant's home was unconstitutional. The Supreme Court affirmed, holding that the warrantless use of a drug-detection dog to sniff the entryway of Defendant's apartment, which was inside of a locked apartment complex, violated her Fourth Amendment rights. Further, the Court found that there was no applicable legal authority permitting the officers' conduct, and therefore declined to apply the good-faith exception to the exclusionary rule (which deems evidence admissible if it was obtained unconstitutionally, but in reasonable, good faith reliance on precedent, statute, or other legal authority). Thus, the Court held that the evidence should be suppressed because without the drug-detection dog sniff, the evidence that formed the basis for the warrant did not establish probable cause to search her home.

Summary of Case Context & HoldingCo-Defendants were convicted of murder, based largely on the eyewitness testimony of the landlord of the apartment where the victim was killed. This eyewitness, a habitual user of crack cocaine and methadone, failed to appear twice in court, and was twice privately questioned by the trial judge about this failure in conversations that were not transcribed, and in the absence of Co-Defendants' counsel, despite their request to be present after the first private discussion. Ordering a new trial, the Court of Appeals held that these conversations, as well as examinations of witnesses privately by a judge or with only one side's counsel present, generally violate the defendants' Sixth Amendment rights to counsel and to confrontation when these examinations pertain to substantive issues—in this case, the eyewitness's credibility.

Summary of Case Context & HoldingDefendant was convicted and sentenced to 45 years for armed violence and unlawful possession with intent to deliver. Officers had found contraband, including drugs and weapons, after searching the home of Defendant's mother pursuant to a warrant. The warrant was based on information provided by a confidential informant. An officer had attested to the informant's reliability and had claimed to have a relationship with the informant. Further, the informant was present at the warrant application proceeding and signed their statement in front of the judge. Defendant argued that the statements in the application were false and moved for a hearing pursuant to the U.S. Supreme Court's decision in Franks v. Delaware, 438 U.S. 154 (1978). Franks held that a defendant can challenge a warrant after showing that officers intentionally or recklessly included a false statement in the warrant application and that the false statement was necessary to establish probable cause. The trial court denied Defendant's repeated motions for a Franks hearing, and the appellate court found such denial to be an abuse of discretion. On appeal, the Supreme Court overruled previous precedent and held that an informant's presence at a warrant application hearing does not foreclose a defendant's opportunity for a Franks hearing. Further, the Court clarified that the proper standard of review for the denial of a Franks hearing is de novo. Accordingly, the Court held that Defendant was entitled to a Franks hearing because he had offered enough evidence to overcome the presumption of the warrant's validity.

Summary of Case Context & HoldingDuring an investigation into the identity of a shooter, police recorded interviews that may have exonerated the Defendant, but were never provided to defense counsel prior to trial. After his conviction for felony murder, the trial court held that his due process rights had been violated under U.S. Supreme Court precedent in Brady v. Maryland, 373 US 83 (1963), and granted him a new trial. In Brady, the U.S. Supreme Court outlined a three-factor test for finding a due process violation when material evidence favorable to the defendant is suppressed. The Michigan Court of Appeal subsequently, in People v. Lester, 232 Mich. App. 262 (1998), added an additional requirement of due diligence for finding Brady violations within state courts. Under this new rule, defendants had to prove that they could not have obtained the suppressed evidence themselves with any reasonable diligence. However, here, the Michigan Supreme Court unanimously found this diligence rule antithetical to Brady because Brady only defines a prosecutorial duty and was not meant to ensure competent defense counsel. However, in addition to overruling Lester, the Court also held that the evidence in question here was not material and, thus, the Defendant could not establish a Brady violation.

Summary of Case Context & HoldingDefendant, who was 24 and suffered from antisocial personality disorder, borderline personality disorder, and fetal alcohol syndrome at the time of the offenses, plead guilty but mentally ill (per 725 ILCS 5/115-2) to first degree murder and one count of robbery. Defendant sought leave to file a postconviction petition on the grounds that, as a functional life sentence imposed without consideration of his intellectual disabilities and age, his 90-year sentence violated the proportionate penalties clause of the Illinois Constitution. The Supreme Court applied the cause-and-prejudice test of section 122-1(f) of the Postconviction Act to both the Defendant’s intellectual disabilities and status as an emerging adult, and declined to extend the holdings of Miller v. Alabama, 567 U.S. 460 (2012) (holding that life sentences without parole are unconstitutional for defendants who were juveniles at the time of their offense) and other Illinois cases to the Defendant’s case. In particular, the Supreme Court noted: (1) prior to Miller, Illinois courts had discretion to consider the age of young adult offenders, that (2) unlike in Miller, Defendant’s de facto life sentence was a discretionary sentence, not a mandatory sentence. Instead, the Supreme Court held that the proportionate penalties clause analysis set forth in People v. Coty, 178 N.E.3d 1071 (Ill. 2020) with respect to a prison sentence of an intellectually disabled defendant, according to which the prospect of neurological development is considered, was also controlling in this case. Because of a record supporting a finding that Defendant’s characteristics were permanent fixtures of his character rather than transitory characteristics due to his age, the Supreme Court affirmed the denial of Defendant’s motion to file a successive postconviction petition.

Summary of Case Context & HoldingDefendant was convicted of being an armed habitual criminal following a bench trial. During his trial, a Chicago police officer testified that he saw Defendant shoot at a moving vehicle. After the vehicle sped off, the officer said she saw Defendant approach a parked vehicle, reach inside the vehicle, and then walk into a nearby house. Defendant was reportedly wearing a blue hoodie. Later, officers found Defendant inside the house, along with a blue hoodie and a handgun that matched the one used in the shooting. Gunshot residue was found on the blue hoodie, but not on Defendant's hands. Officers also found keys to the identified parked vehicle inside Defendant's pocket. On appeal, the appellate court affirmed in part, finding the evidence sufficient to establish guilt beyond a reasonable doubt. However, the appellate court reversed and remanded for a new trial based on the trial judge's "bias in favor of police testimony." The trial judge had stated that the police training of a testifying officer "gave him a better ability than any other witness to identify a face he saw." Thus, the appellate court held that the trial judge afforded that officer more credibility "solely because of his status as a police officer." The Supreme Court affirmed the appellate court's finding that the evidence was sufficient, emphasizing that a single positive identification can be sufficient to support a conviction in the appropriate circumstances. Further, the gunshot residue, car keys, and blue hoodie corroborated the officer's identification. However, the Court reversed the appellate court's finding of judicial bias. The Court found that during the bench trial, the trial judge appropriately considered the credibility of the officer as a witness and exhibited no pro-police bias.

Summary of Case Context & HoldingDefendant, who is intellectually disabled, was found guilty of criminal sexual offenses against a child and originally received a mandatory life sentence. The appellate court found that the sentence failed to consider mitigating factors based on characteristics of intellectually disabled individuals set forth in Atkins v. Virginia, 536 U.S. 304 (2002), and resentenced the Defendant to 50 years imprisonment. The Supreme Court noted that in its view, the mitigating factors in Atkins indicated a continuing danger to reoffend. The Supreme Court looked instead to its prior analysis in People v. Huddleston, 816 N.E.2d 322 (Ill. 2004), which addressed an as-applied, proportionate penalties challenge to the same statute. The Supreme Court held that Section 12-14.1(b)(2) of the Criminal Code's mandatory life sentence for repeated sexual offenses against children, as applied to an intellectually disabled defendant, did not violate the proportionate penalties clause of the Illinois Constitution or the Eighth Amendment, because even if his intellectual disability made him less culpable than the defendant in Huddleston, his age and predominantly static condition made him more likely to reoffend than to be rehabilitated. The Supreme Court further stated that instead of using the Atkins factors, courts should consider the three factors of culpability, future dangerousness, and rehabilitative potential, which it noted had been the subject of comment in the case law, when assessing proportionate penalties clause challenges with respect to intellectually disabled defendants. With respect to the particular Defendant, the Supreme Court noted that it believed it had the authority to reinstate Defendant's original sentence of natural life imprisonment, but would not do so given there was no practical difference from his existing de facto life sentence.

Summary of Case Context & HoldingAt issue was a simultaneous audio and video recording of a controlled drug purchase between a confidential informant and a third party. Both Defendant and the State agreed that the audio recording was illegal pursuant to section 14-5 of the Criminal Code, as the Defendant was not the named subject of the eavesdropping exemption application and thus the audio recording was not within the scope of the authorized overhear. However, the parties disagreed on whether the fruit of the poisonous tree doctrine should be applied to suppress (i) the video recording, which showed evidence of drugs only after the illegal overhear; and (ii) the testimony of the confidential informant, which also occurred after the illegal overhear. Noting that an Illinois circuit court’s ultimate legal ruling on whether suppression is warranted is subject to de novo review, the Supreme Court agreed with the State that, per the plain language of the eavesdropping statute, neither the confidential informant’s testimony nor the video recording was illegally obtained because (i) the confidential informant’s testimony was not eavesdropping; and (ii) without the audio, which the parties agreed was eavesdropping, the recorded video only recorded Defendant’s actions and not an oral conversation. The Supreme Court further found that suppression under the fruit of the poisonous tree doctrine did not apply, since neither the testimony nor the video recording were obtained as a result of the audio recording.

Summary of Case Context & HoldingDefendant was arrested on a robbery charge brought to a station with video recording devices to be interrogated, despite there being a station equipped with such devices nearby. There, the police said the Defendant made statements that incriminated him. At trial, Defendant's counsel requested an "adverse interference instruction" to tell the jury they should question the voluntariness and basic existence of these statements given the absence of an electronic recording, and argued that such instructions should be mandatory whenever the police fail to record an interrogation. The Court of Appeals disagreed, holding that the police have no universal duty to record video interrogations.