State Supreme Court Data Tracker

Summary of Case Context & HoldingDefendant was arrested for murder. After his arrest, Defendant made inculpatory statements to police during interrogation. Defendant moved to suppress the statements on the grounds that they were the result of physical and mental coercion. After he was convicted, Defendant filed a pro se postconviction petition arguing ineffective assistance of counsel and alleging his statements were made involuntarily. The petition was denied. Defendant then filed a claim with the Torture Inquiry and Relief Commission. The Commission found credible evidence of torture and referred the case for judicial review. Defendant was denied relief after both the trial court and appellate court found insufficient evidence of torture. To succeed on a claim of torture, the Supreme Court held that Defendant must show that (1) torture occurred; (2) such torture resulted in a confession; and (3) the confession was used to obtain a conviction. Further, the Court found that a higher degree of proof is required to show torture, and the general voluntariness of statements is not central to this inquiry. Courts must look to the totality of the circumstances. Applying the manifestly erroneous standard of review, the Court found that the trial court did not err in denying Defendant's claim given the inconclusive evidence in the record. The trial court found Defendant's allegations of abuse to be inconsistent and found Defendant himself to be a "wholly incredible witness." For example, Defendant testified that at one point he had been scraped badly on his lower knee, but an officer testified that Defendant appeared fine when he saw him. The trial court found the testifying officer "extremely" credible. The Court deferred to the trial court's ability to determine the credibility of witnesses through live testimony and observation.

Summary of Case Context & HoldingDefendant, who was indicted for aggravated criminal sexual assault and criminal sexual assault in criminal court, argued that the juvenile court had exclusive jurisdiction over the acts he committed when he was 14 or 15 years old, even though he was not charged until he was 23. Looking to the specific language of Section 5-120 of the Juvenile Court Act, defining the "exclusive jurisdiction" of the juvenile court, the Supreme Court found that persons under 21 when charged and younger than 17 when the alleged offenses are committed are the group to be excluded from prosecution in adult criminal court. Furthermore, section 3-6(j), which governs the period within which prosecutions for criminal sexual assault or abuse against a victim who is under 18 years old at the time of the offense, showed the legislature’s intent to allow an extended statute of limitations for sexual offenses committed against children. Specifically, the Supreme Court found the legislature's choice to recognize that both minor assailants and victims age at the same rate, and that without allowing actions to be commenced within 10 years of the victim turning 18 years old, it was foreseeable that the assailants could become adults before the extended statute of limitations had ended. As such, accepting Defendant's argument would go against the clear intent of the legislature. The Supreme Court accordingly rejected Defendant’s due process claim given he was over 21 when charged but encouraged the legislature to reevaluate Section 5-120 in light of the tension between punishments faced by defendants in juvenile court and those faced by juveniles in criminal court for offenses allegedly committed as juveniles.

Summary of Case Context & HoldingDefendant, a high-ranking police officer, was charged with conspiracy and official misconduct for intervening in a larceny case in which the suspect was the son of a police benefactor. Defendant argued that the grand jury should not have heard hearsay statements made by the co-conspirators at times in which the Defendant was not involved, and that the prosecution had not met its evidentiary burden. Looking at the totality of circumstances, the Court of Appeals found that the prosecution had given sufficient evidence, and that hearsay statements from co-conspirators before and after a defendant's involvement in said conspiracy may be admitted into evidence.

Summary of Case Context & HoldingDefendant was convicted of second degree murder, evidence for which included a confession he maintained was false and coerced by police after physical and psychological abuse. One of his interrogators had previously worked on a case allegedly involving a false confession, a fact that the court had suppressed. Defendant then moved to vacate his conviction, arguing that suppressing this fact was a Brady violation—i.e., a violation of a defendants right to receive all evidence the prosecution that could prove his case or hinder the prosecution's. The Court of Appeals maintained the conviction, ruling that no Brady violation had occurred, because the government was not aware of the interrogator's past misconduct at the time of the trial, and had no duty to discover and disclose such information.

Summary of Case Context & HoldingAfter hearing knocks on his door, defendant opened the door of his home to police officers, who then arrested him in the doorway, without a warrant, in relation to several charges of robbery of which he was later convicted. In a motion to suppress, Defendant argued the police had unconstitutionally entered his home without consent or a warrant. The Court of Appeals sided with the police, ruling that warrantless "threshold/doorway arrests" are constitutional, and that police may knock on a door in order to lure a subject to the threshold of a home for this purpose, so long as they do not compel or threaten the subject.

Summary of Case Context & HoldingDefendant was charged and convicted of sexual assault of his 10-year-old daughter. After the appellate court affirmed his convictions, Defendant filed a series of pro se motions. As relevant here, Defendant filed a motion seeking DNA testing pursuant to Illinois' rules of criminal procedure. Defendant maintained his innocence and sought to obtain forensic testing of evidence that he argued was not tested during his trial. At a hearing on the motion, Defendant was accompanied by private counsel who orally requested to make a limited appearance on the matter. The request was denied, and Defendant subsequently appeared pro se to argue the motion. Defendant's motion was also denied. The Supreme Court held that the trial court's denial of private counsel's request was not arbitrary, and Defendant was not denied due process. When requesting to enter a limited appearance, private counsel had not complied with Illinois Supreme Court Rule 13(c)(6)—counsel failed to articulate the scope of his appearance request, he did not file the mandatory notice form, and he did not execute a written agreement with Defendant. The Court stated that the due process right to counsel is not absolute, therefore, procedure rules like 13(c)(6) that govern or limit the scope of attorney representation are constitutional. Regardless, the Court vacated the decision of the trial court and remanded the case to resolve the confusion exhibited by the lower courts when applying Rule 13(c)(6).

Summary of Case Context & HoldingIn In re Abe A., 437 N.E.2d 265 (N.Y. 1982), this Court set forth a three-prong standard for seizure of corporeal evidence from an uncharged suspect that requires bodily intrusion: the State must demonstrate probable cause to commitment of the crime, a "clear indication" that material and relevant evidence will be found, and that the means used for the seizure is "safe and reliable." Generally, when the corporeal evidence sought is not subject to alteration or destruction, there is no exigency and the search warrant application must be brought on notice to the suspect. In this case, the police sought a search warrant authorizing them to obtain corporeal evidence—in the form of DNA evidence by use of a buccal swab—from Defendant, a suspect in a murder investigation who was in custody on an unrelated matter. The Court of Appeals held that there was no violation of defendant’s constitutional rights where he was given notice and an opportunity to be heard prior to the issuance of the warrant on the nature and extent of the bodily intrusion. The Court of Appeals further develops the rule by deciding that Abe and the constitutional right to be free from unreasonable searches and seizures do not require that a defendant be given access to search warrant materials and an adversarial hearing as a matter of constitutional law, as the probable cause determination is one that is made by the neutral magistrate as a matter of course because a buccal swab was undeniably safe, consisted of a minimal intrusion and involved no discomfort, and the method and procedures employed in taking the saliva undoubtedly respected relevant Fourth Amendment standards of reasonableness.

Summary of Case Context & HoldingDefendant swore at officers and claimed they were harassing him in a subway station in Manhattan, after which the officers followed the Defendant to another level of the station, prevented him from leaving, searched him and found an illegal knife. The Defendant moved to suppress the knife on the grounds the police stop was illegal. The Court of Appeals agreed and dismissed the indictment, holding that shouting obscenities at officers does not constitute disorderly conduct.

Summary of Case Context & HoldingDefendant, at trial for attempted armed robbery, was represented by a lawyer from the Legal Aid Society. This lawyer informed the trial court that he was leaving the Legal Aid, after which the trial court rejected a request for adjournment so that a new Legal Aid attorney could have time to prepare themselves for trial. The trial court also relieved the Legal Aid Society over its objections and appointed the Defendant new counsel, at a hearing in which Defendant was present but not consulted. Defendant plead guilty, then sought to withdraw his plea and have new counsel assigned. The Court of Appeals held that relieving Legal Aid as Defendant's counsel without consulting the Defendant deprived him of his Sixth Amendment right to counsel, and that such a claim was not barred by Defendant's guilty plea.

Summary of Case Context & HoldingDefendant was convicted of second degree murder, in part based on a 49.5 hour interrogation during which he did not sleep and only received one meal. On appeal, Defendant argued that statements made during interrogation, as well as subsequent inculpatory statements 10 hours later, should be suppressed as evidence. The Court of Appeals ruled that statements made in both of these interrogations should have been suppressed and that both were tainted by the police misconduct in the initial interrogation

Summary of Case Context & HoldingDefendant was stopped by an officer after driving past an unregistered and therefore legally unauthorized stop sign. After this stop, the Defendant was arrested and charged with both failing to stop at a stop sign and driving while intoxicated. The Defendant argued that the lack of legal authorization for the stop sign created a lack of probable cause for the officer's stop, so no evidence from the stop should be admitted. The Court of Appeals disagreed, ruling that when an officer has an "objectively reasonable" belief that they have probable cause for a stop, the evidence from the stop is admissible as evidence, even if the officer is mistaken that they have such probable cause due to either a mistake in fact or law.

Summary of Case Context & HoldingDefendant, a U.S. permanent legal resident who pled guilty to firearm charges, wished to withdraw his plea because he was not informed by counsel that a guilty plea could have potential immigration consequences. Defendant acknowledged that the Supreme Court had previously addressed a similar question in People v. Delvillar, 922 N.E.2d 330 (Ill. 2009), involving deportation consequences, and held that such an admonishment was direct, not mandatory–meaning that any immigration consequences would be collateral (i.e., not within the circuit court's authority to impose) and not direct (i.e., affecting a defendant's sentence and other punishments within the circuit court's authority to impose). Because of the collateral vs. direct distinction, the Supreme Court had held in Delvillar that "the failure to admonish a defendant of potential immigration consequences does not affect the voluntariness of the plea” or violate due process. However, Defendant argued that the Supreme Court needed to reevaluate that conclusion in light of Padilla v. Kentucky, 559 U.S. 356 (2010), in which the U.S. Supreme Court held that deportation resulting from a criminal conviction is uniquely difficult to classify as either a direct or collateral consequence. The Supreme Court distinguished the current case with Padilla because Padilla involved a Sixth Amendment claim regarding ineffective assistance of counsel, while both Delvillar and Defendant brought Fifth Amendment due process claims. The Supreme Court held that Padilla did not overrule Delvillar, and thus the failure to admonish a defendant of potential immigration consequences does not affect the voluntariness of the plea or violate due process.

Summary of Case Context & HoldingDefendant was charged with three assaults on three separate deputy sheriffs based on a fight at a correctional facility. The Defendant claimed a deputy initiated this fight. The deputies denied this and alleged to have watched a video recorded by the facility that proved their case, a video that was destroyed before trial. At trial, a request for an "adverse inference charge" to the jury, instructing them to question the validity of the testimony by the deputy about the existence and contents of the video, was denied. The Court of Appeals held that such a charge should be given where a defendant has requested evidence likely to be important to the case, and where this evidence has been destroyed by the State.

Summary of Case Context & HoldingDefendant Hardman was found in possession of heroin with intent to deliver within 1000 feet of an elementary school. After being found guilty, Hardman appealed, arguing that the building at issue was not operating as a school on the date of the offense because the building was in transition around the time. Specifically, Hardman insisted that the location must be "active" or "operating" at the time of the offense. On appeal, the appellate court held that testimony put forth by the arresting officers was sufficient to determine that the building near the offense was a school. The Supreme Court held that the statutory language in question does not allude to any "use" requirement in the context of a school locality. The Court explained that requiring particularized evidence as to a school building's active or operational status on the day of an offense would go against the statute's plain language and conflict with the legislature's intent.

Summary of Case Context & Holding"[W]hen a defendant has been convicted of an armed felony and the only barrier to his or her youthful offender eligibility is that conviction, the court is required to determine on the record whether the defendant is an eligible youth by considering the presence or absence of the factors set forth in CPL §720.10 (3)" (People v Middlebrooks, 35 N.E.464 (N.Y. 2015); accord People v Lofton, 81 N.E.3d 839 (N.Y. 2017)). Here, the State conceded that the sentencing court failed to make any appropriate on-the-record determination. The Court of Appeals accepted the State's concession and, accordingly, the case should be remitted for consideration of youthful offender treatment.

Summary of Case Context & HoldingAfter his conviction, Defendant challenged the state’s extortion statute. The Court held that the plain language of the statute defines extortion as occurring “when a defendant maliciously threatens to injure another person with the intent to compel that person to do any act against his or her will, without regard to the seriousness or significance of the compelled act.” Further, the Court held that the same statute is not void for vagueness under the First Amendment because it gives a person of ordinary intelligence a reasonable opportunity to know what conduct is prohibited. This holding overruled two Court of Appeal decisions that imparted a requirement that compelled acts under the statute be of a certain level of seriousness.

Summary of Case Context & HoldingWhile being processed for an arrest at the Franklin County Jail, Defendant was directed to remove his footwear, a command given to all those in custody at jail, but Defendant refused to do so despite multiple orders regarding this. A police sergeant called for backup and specifically warned Defendant that he would pepper spray Defendant if he refused to remove his footwear. Defendant continued to refuse, was pepper sprayed in the face, and punched the sergeant in the head. Defendant was charged with assault in the second degree. The Appellate Division concluded that there was a reasonable view of the evidence that the use of the pepper spray constituted excessive force. The Court of Appeals, viewing the evidence in the light most favorable to Defendant, decided that Defendant's contention that the force exerted was unlawful is without merit, and no reasonable factfinder could conclude on this record that Defendant reasonably believed that the use of force was necessary to defend himself from the use of unlawful physical force. Order reversed and case remitted to the Appellate Division.

Summary of Case Context & HoldingPolice officers, having observed Defendant exit and reenter a building in a public housing development several times, possessed the requisite objective credible reason to approach him and ask briefly about his identity, destination, or reason for being in the area. However, after Defendant explained that he was visiting a friend who lived in the building, and provided his identification, the encounter rose beyond a level-one request for information, which, according to the Court of Appeals, the State failed to justify as lawful. An officer took Defendant's identification to the eleventh floor of the building to verify whether the occupant of the apartment Defendant identified knew him, while another officer instructed Defendant to "stand right there" under the watch of two officers, and when the first officer returned, having determined that the occupant of the apartment did not know Defendant, Defendant was arrested for trespassing. The State justified the officers' interaction with Defendant purely on the ground that it was a level-one inquiry supported by an objective credible reason. The Court of Appeals found that the record demonstrated that the encounter thereafter rose beyond a level-one request for information, which the State failed to justify as lawful. Accordingly, Defendant's motion to suppress drugs recovered from his person during a search incident to his arrest was granted.

Summary of Case Context & HoldingDefendant, who was convicted of attempted murder and sentenced to 40 years’ imprisonment, filed a pro se postconviction petition alleging that his mandatory 25-year firearm sentencing enhancement violated the proportionate penalties clause of the Illinois Constitution because he was 18 years old when he committed the offense. Defendant alleged that even though he was not a minor, there was new scientific research showing that young adults are less morally culpable as brain maturation continues into the early twenties, and that despite his chronological age of 18 years, his cognitive abilities were on par with that of a 16 or 17 year old. Defendant alleged that there were several factors showing his rehabilitative potential, including that he had never been involved in a gang and had a close relationship with his mother and siblings. Defendant also pointed to his presentence investigation report, which showed a troubling social history but lack of gang involvement and close family relationships, to support his rehabilitative potential. The Supreme Court declined to extend People v. House, 185 N.E.3d 1234 (Ill. 2021), in which the Supreme Court held that the appellate court erred in holding that House’s natural life sentence violated the proportionate penalties clause as applied to him without a developed evidentiary record or factual findings, because unlike the current case, House involved a mandatory life sentence. The Supreme Court further emphasized that the distinction between a juvenile and adult has consistently been drawn at age 18, including by the U.S. Supreme Court in Roper v. Simmons, 543 U.S. 551 (2005), in which the U.S. Supreme Court referred to the age of 18 as "where society draws the line for many purposes between childhood and adulthood" despite individual differences in maturity.

Summary of Case Context & HoldingDefendant, who was charged with resisting a peace officer and disorderly conduct, entered a negotiated guilty plea while represented by retained counsel. Subsequently Defendant filed a pro se motion to vacate the guilty plea and judgment. The Defendant’s counsel withdrew, a public defender was appointed for the Defendant, and the parties convened in court with respect to Defendant’s consolidated misdemeanor cases, which included a new charge for criminal trespass. The prosecutor and Defendant's attorney agreed to a court-ordered fitness evaluation, in which the evaluator found the Defendant to exhibit disordered thinking. The court ordered Defendant to be placed into a secure facility. Defendant appealed on the basis that she was denied the effective assistance of counsel. Defendant further argued that the usual two-part test for ineffective assistance cases, requiring a showing of prejudice, did not apply because, in her view, counsel failed to subject the prosecution’s case to "meaningful adversarial testing." Although the parties agreed that with the Defendant’s restoration to fitness the question was moot, the Supreme Court agreed to review on the grounds that the public interest exception (allowing the Supreme Court to consider questions likely to recur). Defendant argued that when the State raises a bona fide doubt about a defendant’s pre-trial fitness, defense counsel is constitutionally obliged to fight for a finding of fitness regardless of the evidence under United States v. Cronic, 466 U.S. 648 (1984) and People v. Hattery, 488 N.E.2d 513 (Ill. 1985). The Supreme Court distinguished Defendant’s case (which involved a threshold consideration that governs whether defendant may, consistent with due process, be tried at all) from Cronic and Hattery, which concerned counsel’s failure to advocate for a defendant’s position. Thus, the Supreme Court held that the Defendant’s attorney did not render ineffective assistance of counsel by arguing that the Defendant was unfit for trial where the attorney believed that to be the case and the evidence supported that conclusion, even though the Defendant believed otherwise.

Summary of Case Context & HoldingDefendant, who was convicted of first degree murder and aggravated kidnapping, filed a postconviction motion alleging, among other issues, that his mandatory life sentence violated the Eighth Amendment and the proportionate penalties clause of the Illinois Constitution (Ill. Const. 1970, art. I, § 11) because the trial court had failed to consider mitigating factors, such as age, level of culpability, and criminal history, as well as new scientific evidence on juvenile maturity and brain development. The Supreme Court noted that no other courts had made factual findings solely based on such scientific evidence. Because Defendant did not provide or cite evidence as to how evolving science on juvenile maturity and brain development applied to him specifically, as opposed to all young adults, the Supreme Court remanded for the trial court to hold an evidentiary hearing.

Summary of Case Context & HoldingUnder Illinois Criminal Code Section 11-9.3(b), a convicted child sex offender may not knowingly loiter within 500 feet of a school while persons under the age of 18 are present. Defendant was parked in front of the school in his car when a police officer saw him, ran his license plate, and subsequently arrested him. While undergoing arrest, Defendant claimed that he was only within 500 feet of the school because he was waiting for his friend to deliver lunches to the friend's grandchildren, which was corroborated when the friend arrived during the arrest. At trial, Defendant further argued that he was not loitering or sitting idly in their car, but rather waiting and sitting with a legitimate purpose. The trial court ruled that the Defendant had been in "direct violation" of Section 11-9.3(b). The appellate court affirmed, holding that any child sex offender who is neither a parent nor a guardian of a child attending a school loiters when they remain within the restricted school zone for any purpose while children are present. On appeal, the Supreme Court agreed with the appellate court, holding that a child sex offender may loiter within the meaning of Section 11-9.3(b) simply by knowingly remaining or staying within 500 feet of a school while persons under 18 are present. The purpose for being near the school was not relevant, and the statutory language was not vague.

Summary of Case Context & HoldingDefendant was convicted of first-degree murder for the shooting deaths of two individuals. Prior to trial, Defendant moved to suppress statements obtained by officers before his arrest, including a taped recording of officers' interrogation of Defendant and Defendant's subsequent confession. Defendant argued that the confession was involuntary and obtained as a result of inadequate Miranda warnings and physical coercion. The motion to suppress was denied, and Defendant was found guilty. Defendant's subsequent motion for a new trial was similarly denied. In front of the appellate court, Defendant argued for the first time that his age, education, mental health, and substance abuse contributed to the involuntariness of the confession. The appellate court agreed and suppressed the confession. On appeal the Supreme Court found that Defendant failed to introduce an account of these factors in the trial court record. Accordingly, the Supreme Court concluded that the appellate court erred in relying on the new information because it was raised for the first time on appeal and had not properly been preserved.

Summary of Case Context & HoldingThe Court of Appeals considered whether, Defendant, a youthful offender, was entitled to a jury instruction on voluntary possession of a weapon. Defendant testified that, while sitting in an apartment where he had rented a room for the evening, he was shot by someone outside of the apartment. He further testified that, after running into the bedroom he had rented to search for a towel to stop the bleeding from his gunshot wound, he saw what appeared to be a gun in an open drawer. Police arrived shortly thereafter and transported Defendant to the hospital. Police also searched the apartment and found a number of weapons and marijuana. Defendant was charged with criminal possession of a weapon and unlawful possession of marihuana. With respect to the gun found in the drawer, Defendant argued that the jury should be instructed that possession had to be voluntary, meaning that he “was aware of his . . . physical possession or control . . . for a sufficient period to have been able to terminate the possession” (CJI2d [NY] Possession—Voluntary Possession § 15.00 [2]). The Court of Appeals held that, when the evidence was viewed in the light most favorable to Defendant, there was a reasonable view that he had constructively possessed the weapon but that his awareness was so fleeting that any possession was not voluntary. The Court of Appeals thus concluded that the evidence supported the requested jury charge and the error warranted a new trial on the voluntary possession count.

Summary of Case Context & HoldingDefendant was convicted of first-degree murder and aggravated battery arising out of a shooting at a gas station in Chicago. The prosecution relied on several witness statements that inculpated Defendant in the shooting. During the jury trial, the witnesses recanted their statements, testifying that they were the result of severe intimidation and coercion by police officers. The statements were nonetheless admitted, and Defendant was found guilty. Defendant later moved for leave to file a successive postconviction petition, claiming his innocence and alleging that his due process rights were violated when the State relied on coerced witness statements during trial. Filing a successive postconviction petition is permitted under the Act where (1) the defendant raises a constitutional claim by satisfying the cause-and-prejudice test (i.e., by showing that (i) some external objective factor prevented him from raising the defense in the initial postconviction proceeding, such that (ii) the error so inflected his trial as to violate due process); or (2) the defendant asserts a claim of actual innocence. The trial court denied the motion, and the appellate court affirmed. The Supreme Court held that Defendant failed to show that he was prejudiced by the absence of new evidence of police misconduct. To support this claim, Defendant attached documents listing complaints lodged against the detectives who interviewed each eyewitness in his case. These complaints did not relate to witness intimidation or coercion, and accordingly the Court found that they were irrelevant to the claim. Defendant also attached documents relating to lawsuits brought against two detectives in the case, but both concluded with no findings of wrongdoing against the detectives and as such were also irrelevant. Second, the Supreme Court held that Defendant also failed to establish a claim of actual innocence. To support his innocence, Defendant offered new affidavits from three witnesses. However, none of these affidavits offered evidence that was not already presented at trial. Therefore, this information was not “newly discovered,” and principles of fundamental fairness do not require a successive postconviction hearing.

Summary of Case Context & HoldingHere, the Supreme Court updated state precedent to match the U.S. Supreme Court precedent in Crawford v. Washington, 541 US 26 (2004) regarding confrontation rights. Under the 6th amendment, criminal defendants are guaranteed the right to confront the witnesses against them. Under Crawford, this 6th amendment right requires a face-to-face cross-examination for testimonial evidence unless a witness is unavailable, and the defendant had a prior opportunity for cross-examination. In this case, the Defendant was convicted on the basis of a sexual assault occurring in 1996, although analysis—which led to the subsequent conviction—on the relevant rape kit was not done until 2015. The prosecution moved and was allowed, despite Defendant’s objections, to have the analyst testify via two-way, interactive video. The Supreme Court of Michigan interpreted Crawford as drawing a bright-line rule requiring a face-to-face encounter for testimonial evidence. Thus, the Supreme Court determined that allowing the testimony in this case violated Defendant’s state and federal constitutional rights to confrontation.

Summary of Case Context & HoldingDefendant was questioned for 28 hours across three days about the death of a former partner and her brother, during which he confessed to their murders, along with related crimes. The Defendant moved to suppress his statements to the police, saying they were coerced and that he did not knowingly and intelligently waive his Miranda rights due to his limited English proficiency. The Court of Appeals held that, while the delays by the police were unnecessary, the totality of circumstances—e.g., the Defendant was supplied with food, water, and cigarettes, the interrogation was not continuous and allowed Defendant breaks to sleep and consider his situation, and conversed multiple times with officers in English—showed that Defendant's statements were voluntary.

Summary of Case Context & HoldingThe circumstances (as described below) did not warrant a level three De Bour stop and frisk (which requires reasonable suspicion determination by the officer), and the evidence seized as a result of the frisk had to be suppressed where the officer's observations of Defendant moving from the driver's seat to the passenger seat of his parked car, moving his upper torso back toward the driver's seat, pulling up his pants and attempting to buckle his belt, and appearing nervous while being questioned did not support a reasonable view that Defendant was armed, had committed a crime, or was about to commit a crime. Thus, the officer lacked reasonable suspicion to justify the stop and frisk after Defendant exited a parked car and walked down the street.

Summary of Case Context & HoldingDefendant, while held in Rikers Island on robbery charges, made several incriminating statements during phone calls to friends and family, which, per Department of Correction's policy, were recorded and handed over to the prosecution. At trial, the Defendant argued that the Department's practice of recording and disseminating to District Attorneys' offices all non-privileged and non-exempted phone calls from inmates violated inmates' right to counsel. The Court of Appeals sides with the prosecution, holding that no agent of the government deliberately elicited incriminating statements from inmates on these phone calls and notes that Defendant had several notices that his calls were being recorded, while also stating this ruling should not be viewed as the court of appeals approving of this policy.

Summary of Case Context & HoldingDefendant was driving when she swerved into an adjacent lane and struck another vehicle. Two people in the other vehicle were killed and defendant was taken to the hospital. At the time, Defendant was 34 weeks' pregnant and the hospital found signs of fetal distress so she agreed to an emergency cesarean section. The baby died six days later. The autopsy confirmed the cause of death was due to injuries sustained during the accident. The Defendant was indicted on three counts of manslaughter, one count of aggravated vehicular homicide, and one count of operating a vehicle while under the influence. Defendant was traveling in excess of 50 mph in a 30 mph zone, while under the influence of a prescription drugs and alcohol, and was not wearing a seat belt. Defendant was only convicted on manslaughter in the second degree for the death of her child. The Court of Appeals reversed holding the legislature did not intend to hold pregnant women criminally responsible for engaging in reckless conduct against themselves and their unborn fetuses, such that they should be subject to criminal liability for prenatal conduct resulting in postnatal death.

Summary of Case Context & HoldingDefendant was convicted for a murder based on DNA that was not tested for two decades and included a mix of results. At trial, Defendant was denied a request to have a DNA expert appointed to testify to the test results. The Supreme Court clarified that the U.S. Supreme Court holding in Ake v. Oklahoma, 470 US 68 (1985) governs the due-process analysis to determine if a defendant is entitled to the appointment of an expert witness at government expense. Further, the Supreme Court also adopted a reasonable-probability standard from the Eleventh Circuit (Moore v. Kemp, 809 F2d 702 (11th Cir. 1987)) to determine if a defendant has made a sufficient showing to meet the standard from Ake. This case was remanded for this analysis.

Summary of Case Context & HoldingDefendant Rodney Lee Koon was charged with operating a motor vehicle under controlled substances in violation of MCL 257.625(8). When stopped for speeding, he informed the police officer that he had a medical marijuana registry card and admitted that he had smoked marijuana five to six hours earlier. A blood test showed that Koon had tetrahydrocannabinol (THC) in his bloodstream. The Court concluded that defendant’s registration under the Michigan Medical Marihuana Act (MMMA), MCL 333.26421 et seq., protected him from prosecution under MCL 257.625(8) unless the prosecution was able to prove that Koon was actually impaired by the presence of marijuana in his body. The circuit court affirmed, concluding that the MMMA superseded the zero-tolerance provision of MCL 257.625(8). The court of appeals, reversed, noting that the MMMA prohibited registered medical marijuana patients from operating a motor vehicle while under the influence of marijuana. On review, the Supreme Court reversed and remanded, holding that (1) a patient registered under the MMMA is allowed to drive when they have indications of marijuana in their system but not otherwise under the influence of marijuana; and (2) the MMMA's prohibition against driving while "under the influence" of marijuana contemplates something more than having any amount of marijuana in one's system and requires some effect on the person.

Summary of Case Context & HoldingWithout obtaining a warrant, police officers attached a GPS device to Defendant’s vehicle. Defendant was convicted of aggravated robbery, robbery, and burglary. While Defendant's appeal was pending, the U.S. Supreme Court decided United States v. Jones, 565 U.S. 400 (2012) and Davis v. United States, 564 U.S. 229 (2011). The Court in Jones found that attaching a GPS device to a car and using the device to track the car’s movements constitutes a search under the Fourth Amendment. The Court in Davis, held that the good-faith exception to the exclusionary rule (which generally deems evidence admissible when officers act in good faith and reasonably rely upon existing legal authority) applies when an officer reasonably relies on binding precedent when searching a car. At the time of the officers' actions in this case, the U.S. Supreme Court had issued two opinions holding that installation of a GPS device and subsequent monitoring of movement is constitutional. These cases were: (1) United States v. Knotts, 460 U.S. 276 (1983), where officers attached a tracker to a container and the container was subsequently placed inside a monitored moving vehicle; and (2) United States v. Karo, 468 U.S. 705 (1984), where officers placed a tracker inside a canister that was also placed into a monitored moving vehicle. The Illinois Supreme Court applied the good-faith exception to this case and found that it was objectively reasonable for officers to rely on Karo and Knotts, as Jones had not yet been decided. Therefore, suppression of the evidence was not warranted because the officers acted in good faith when installing the GPS device on Defendant's vehicle and using it to track Defendant's movements.

Summary of Case Context & HoldingDefendant, who was serving consecutive sentences for crimes related to the unlawful possession of controlled substances, filed a petition for postconviction relief based on the claim that the circuit court forced him to proceed pro se. The Supreme Court noted that Defendant’s first appointed counsel withdrew after Defendant chose to secure private counsel, who withdrew after Defendant failed to appear at a hearing. Defendant subsequently refused to cooperate with, and acted aggressively toward, his second appointed counsel, after which he received a warning from the court that his options were to work with the public defender, hire private counsel, or represent himself. The Supreme Court held that Defendant voluntarily, knowingly, and intelligently waived Illinois's statutory right to appointed counsel in postconviction proceedings through his actions. In particular, the Supreme Court noted that under Patterson v. Illinois, 487 U.S. 285, 292 (1988), a defendant must have both a full awareness of the nature of the right being abandoned and the consequences of the decision to abandon the right. Here, Defendant told his second appointed counsel, Kramarsic, that he wanted nothing to do with Kramarsic and that he disagreed with Kramarsic's theory of the case. Defendant also yelled obscenities at Kramarsic and at one point grabbed papers in a physically belligerent manner. Defendant was repeatedly informed that Kramarsic would be the last counsel appointed for him by the court. Accordingly, a verbal waiver was not necessary since he was expressly warned that his continued conduct would result in such a waiver.

Summary of Case Context & HoldingAfter Defendant was convicted of involuntary manslaughter by a jury for the death of his wife, the trial court exceeded state sentencing guidelines based on factors not previously included when calculating his minimum sentence range. While on appeal, the U.S. Supreme Court decided Alleyne v. United States, 570 U.S. 99 (2013), which extended the U.S. Supreme Court's holding in Apprendi v. New Jersey, 530 U.S. 466 (2000). In Apprendi, the U.S. Supreme Court found a 6th amendment violation if any fact increasing the penalty of a crime was not submitted to a jury for beyond a reasonable doubt analysis. In Alleyne, the U.S. Supreme Court extended this rule to mandatory minimum sentences. Here, the Court allowed Defendant to submit supplemental briefings in light of this new decision and ultimately found Michigan’s sentencing guidelines, under which Defendant was sentenced, constitutionally deficient under Alleyne. These sentencing guidelines were struck to the extent they allow judicial factfinding beyond that of the jury. However, because Defendant did not object at sentencing on Apprendi/Alleyne grounds, the appropriate review in his case was for plain error affecting substantial rights. Defendant could not do so and, thus, his sentence was ultimately affirmed.

Summary of Case Context & HoldingDefendant, who was 16 at the time of the offenses and 23 at the time of trial, was convicted of first degree murder, aggravated criminal sexual assault, and home invasion and sentenced to 130 years’ imprisonment. Defendant filed a motion for leave to file a successive postconviction petition, arguing that his sentencing hearing was constitutionally inadequate under Miller v. Alabama, 567 U.S. 460 (2012) because the trial court did not discuss his youth and its attendant characteristics in mitigation but rather only gave a generalized statement about his age. The Supreme Court reviewed the proceedings, including the trial court’s consideration of Defendant’s age, maturity, family, and home environment, prospects for rehabilitation, and other Miller factors, and the trial court's conclusion that no mitigating factors applied but that aggravating factors applied, in that the manner of the victim's death and Defendant's ownership of weapons showed a choice by the Defendant to choose a "life of showing no respect for human life." Specifically, there was no evidence provided regarding incompetence or mental health. Furthermore, Defendant had a criminal history that included aggravated discharge of a firearm, an adult misdemeanor conviction, and an aggravated battery charge for an incident that had occurred in jail while he was awaiting trial. The Supreme Court further noted that Defendant had "had every opportunity to present mitigating evidence but chose not to offer any" and that the trial court had considered Defendant's youth and its attendant circumstances. Accordingly, the Supreme Court held that Defendant's de facto discretionary life sentence was not unconstitutional under the Eighth Amendment.

Summary of Case Context & HoldingDefendant Cynthia Mazur, wife of David Mazur, was both a registered qualifying patient and a registered primary caregiver for two medical marijuana patients. David grew marijuana in their marital home. Officers of the Holly Police Department, acting on a tip, searched the residence for marijuana. Here, the Supreme Court considered whether the application of the Michigan Medical Marihuana Act's (MMMA) immunity provisions applied to individuals who were neither registered qualifying patients nor primary caregivers. The Supreme Court held that (1) Defendant was not entitled to immunity under MCL 333.26424(i) of the MMMA because Defendant was not merely assisting her husband with conduct involving the actual ingestion of marijuana but instead assisted him with the cultivation of marijuana; (2) assisting in the cultivation of marijuana did not constitute assistance with "using" or "administering" marijuana; (3) Defendant provided her husband, who was both a qualifying patient and a registered caregiver, with sticky notes for the purpose of detailing the harvest dates of his plant, which constituted the provision of "marihuana paraphernalia" because the objects were actually used in the cultivation of marijuana; and (4) the prosecution was prohibited from introducing the evidence relating to defendant's provision of the sticky notes as a basis for the criminal charges against her.

Summary of Case Context & HoldingDefendant was a passenger in a car when they were pulled over and his backpack was searched by police. The search led to Defendant’s conviction for possession of meth as a habitual offender. The Supreme Court used this opportunity to overturn its own precedent in People v LaBelle, 478 Mich 891 (Mich. 2007) to find that a passenger’s personal property is not subsumed by the vehicle that carries it for federal Fourth Amendment purposes—so long as the passenger has an otherwise reasonable expectation of privacy in that property.

Summary of Case Context & HoldingTwo Defendants pled and were found guilty, respectively, for armed robberies committed when they were 18 years old. Many crimes committed by 16- to 19- year old are categorically eligible for determination of Youth Offender status, which comes with more favorable sentencing, based on the case People v. Rudolph, 997 N.E.2d 457 (N.Y. 2013). Defendants argued that their status as "eligible youth" requires that they should have received a Youth Offender determination, however, armed robberies are only eligible for this more favorable sentencing in the presence of mitigating factors. The Court of Appeals found that such mitigating factors were not present, and as a result, neither Defendant received Youth Offender determinations.

Summary of Case Context & HoldingDefendant, at age 18, plead guilty to several assault and attempted murder charges and was denied Youth Offender status based in part from a confidential document that was not shared with nor disclosed to the defendant. Defendant argued that he was entitled to an explanation of the reasoning for denying him this status as well as to disclosure of the confidential document. In looking at CPL § 720.20, the Court of Appeals held that a defendant is not entitled to the reasoning behind the denial of Youth Offender status. However, in this particular case, Defendant's due process rights were violated by the sentencing court refusing to disclose the confidential document.

Summary of Case Context & HoldingCity of Chicago police officers responded to a call about a person with a gun at a park. Responding officers approached a group of teenagers, and the 19-year-old Defendant first walked away before running out of the park. An officer witnessed him remove an uncased pistol from his waistband and throw it on the ground. The gun was found to be fully loaded. Upon arrest, the Defendant did not present a valid Firearm Owner Identification (FOID) card. The State charged the Defendant with one count of unlawful use of a weapon and six counts of aggravated unlawful use of a weapon (AUUW) for having a loaded, uncased, and immediately accessible weapon both on his person and in public, without a valid FOID card, while under the age of 21. The trial court found the Defendant guilty on all seven counts. On the Defendant’s post-trial motion, the trial court vacated its guilty finding on the UUW charge because the State failed to carry its burden. The trial court also requested supplemental briefing on the constitutionality of the AUUW statute’s mandatory imprisonment sentence, under the proportionate penalties clause and the due process clause of the Illinois Constitution, both facially and as applied. After oral argument, the trial court found the provisions of the AUUW statute unconstitutional and instead entered a guilty finding on lesser included offenses of UUW. The State appealed directly to the Illinois Supreme Court. On appeal, the Defendant first argued that the Supreme Court lacked appellate jurisdiction because the trial court had effectively acquitted him. But the fact that the trial court had initially entered a finding of guilt indicated that the State had established the factual prerequisites for guilt such that no acquittal occurred on the subsequent unconstitutionality finding. On the merits, the Defendant argued that the statute was unconstitutional under: (1) the right to bear arms; (2) the due process rights under the federal 14th Amendment and the state constitution; (3) the proportionate penalties clause of the state constitution; and (4) the federal and state constitutional due process and equal protection provisions. During the period between the trial and the appellate sitting, the Supreme Court issued an opinion finding a portion of the relevant statute unconstitutionally infringed on the right to carry a gun on one’s person. People v. Aguilar, 2 N.E.3d 321 (Ill. 2013). The Supreme Court therefore extended Aguilar which unconstitutionally prohibited the carrying of a gun on one’s person in a public way. The Supreme Court rejected the Defendant’s argument that this finding rendered the remainder of the statute unconstitutional because those provisions were severable. The Defendant also challenged the AUUW statute’s prohibition on minor possession of a weapon and the requirement of a valid FOID card. First, the Supreme Court determined that the Second Amendment is not absolute, and that because age is not a suspect class, the legislature must only exhibit a rational purpose in restricting and conditioning the right of those under 21 years of age to possess a firearm. Neither did the age and FOID requirements violate the Defendant’s federal or state equal protection rights. Again, the Supreme Court stated that strict scrutiny did not apply because neither subsection “burden[ed] a fundamental right at the core of the second amendment” and because age is not a suspect class. The legislature had a rational purpose in preventing those under 21 from possessing in public a handgun. Finally, the Supreme Court rejected the trial court’s finding that the FOID requirement violated the Defendant’s due process rights both facially and as applied by imposing “special burdens” on him and those similarly situated. The FOID Card Act required a minor wishing to possess a gun to obtain parental consent. But because both of Defendant’s parents had felony convictions preventing them from obtaining their own FOID cards, he argued that he could not provide the requisite consent. The Supreme Court rejected this as-applied challenge because the trial court failed to conduct a trial or establish an evidentiary record on this issue. The Supreme Court also rejected the facial challenge because, even if such a minor as the Defendant could not obtain parental consent, the statute provided a mechanism for special review of permit applications by the Director of the Department of State Police. The Supreme Court concluded by finding that the statute’s sentencing provision was unconstitutional. In particular, a portion of the statute incorporated and required a finding under another portion of the statute and was not severable from that other portion, which was unconstitutional. And having found the portion of the statute unconstitutional due to the Second Amendment analysis, the Supreme Court declined to address the Defendant’s argument brought under the proportionate penalties clause of the state constitution.

Summary of Case Context & HoldingDefendant moved to dismiss charges of driving while his ability were impaired in front of a judge in city court, who denied the motion. This same judge then proceeded over both the bench trial in which the Defendant was ultimately convicted, and the county court trial in which the Defendant appealed this conviction. The Court of Appeals decided that a judge who presided at a trial may not act as the appellate judge in the same case, as they would likely not be or appear to be an impartial jurist. This ban does not apply to judges who proceed over different stages of a trial, since at this stage there is still the availability of further appellate review.

Summary of Case Context & HoldingDefendant, charged with murder based on confessions during an interrogation, was assessed by psychiatric experts to have issues of concentration, memory, intelligence and auditory hallucinations. His counsel at trial decided not to execute subpoenas for or otherwise review these assessments as evidence of Defendant's mental weakness, which could have rebutted the voluntariness of his admissions, due both to poor strategy and a misunderstanding of criminal discovery law. After sentencing, Defendant obtained new counsel which moved to vacate the conviction, arguing trial counsel's failures represented ineffective representation. The Court of Appeals held that Defendants' right to representation was violated by his counsel's failure to secure and review crucial documents to Defendant's case. A strategy involving "a total failure to investigate the facts of a case, or review pertinent records," does not constitute meaningful representation.

Summary of Case Context & HoldingUsing the emergency lights on his unmarked Chevrolet Tahoe, a federal marine interdiction agent with the U.S. Customs and Border Protection (CBP) stopped the driver of a vehicle in which Defendant was a passenger for driving dangerously on a public highway. After pulling the driver over, the agent waited in his truck for police officers who, upon arriving at the scene, searched the vehicle and arrested defendant for criminal possession of a weapon. The question on this appeal is whether the courts below properly relied on this Court's decision in People v. Williams, 829 N.E.2d 1203 (N.Y. 2005), in granting Defendant's motion to suppress the evidence recovered. The trial court concluded that suppression was warranted under Williams because, by activating his emergency lights to pull the driver of the vehicle over and approaching the car with the Buffalo police officer, the agent "acted under the color of law with all the accouterments of official authority and could not effect a citizen's arrest." The Court of Appeals decided that Williams is inapposite because the CBP agent who stopped Defendant was not considered a federal law enforcement officer with peace officer powers pursuant to CPL §2.10 and CPL §2.15, he could not have improperly circumvented the jurisdictional limitations on the powers reserved for those members of law enforcement under CPL § 140.25. Therefore, the trial court should have denied Defendant’s motion to suppress the gun found as a result of a traffic stop, called in by the agent, and the appellate court erred by affirming suppression of the evidence.

Summary of Case Context & HoldingThe Supreme Court extended its holding in People v. Taylor, 987 N.W.2d 132 (Mich. 2022) to eighteen-year-olds just past the cusp of being considered “juvenile.” As in Taylor, the Supreme Court considered scientific and social-science research regarding the neuroplasticity of the adolescent brain that leads to impulsivity, recklessness, and risk-taking. The Supreme Court also considered that young persons will inevitably serve more time than older offenders making that sentence less proportional to their crimes. Therefore, the Supreme Court concluded that automatic condemnation to die in prison at eighteen was cruel and the logic about why children differ from adults for sentencing applies in equal force to eighteen-year-olds. The defendant had his sentence vacated and case remanded for re-sentencing under this new rule.

Summary of Case Context & HoldingDefendant, who was 15 at the time of his station-house confession, was convicted of aggravated criminal sexual assault after being automatically transferred to criminal court. On appeal, Defendant argued, among other things, that his confession should be suppressed as involuntary, in part because of ineffective assistance by counsel at the pretrial suppression hearing. Defendant did not allege threats, mistreatment, or coercion by the police, nor did he claim to have failed to understand the interrogation process or ask to speak to an adult. The Supreme Court noted that the relevant factors in examining the totality of the circumstances of the confession were (1) Defendant's age; (2) his limited experience with the criminal justice system; (3) any possible police deception; and (4) the time, legality, and duration of the questioning. The Supreme Court found that Defendant failed to establish that even if Defendant’s counsel had offered evidence of diminished mental capacity at the suppression hearing or requested a pretrial fitness hearing, there was a reasonable probability that the outcome would have been acquittal. The Supreme Court further held that even though the conduct of police may not have been exemplary, the police made a reasonable attempt to notify a concerned adult (as required by statute) and the detective assigned as a youth officer did not act improperly.

Summary of Case Context & HoldingA police officer stopped Defendant's car because of a nonfunctioning center brake light. Defendant, who exhibited signs of intoxication, was given—and failed—a portable breathalyzer test. Defendant was arrested and charged with operating a motor vehicle while impaired (Vehicle and Traffic Law § 1192) and two counts of operating a motor vehicle while intoxicated. Defendant moved to suppress the evidence obtained as a result of the stop, asserting that the officer lacked probable cause to justify the seizure. The sole issue on appeal is whether the officer's belief that Defendant violated the Vehicle and Traffic Law by operating a vehicle with a nonfunctioning center stop light was objectively reasonable. The Court of Appeals concluded that the officer's interpretation of the Vehicle and Traffic Law was objectively reasonable because the law mandates that motor vehicles must be equipped with at least two functioning stop lamps. Therefore, the courts below erred as a matter of law in granting Defendant's suppression motion.

Summary of Case Context & HoldingThe Court of Appeals held that Defendant was properly assessed points under Sex Offender Registration Act (SORA) risk assessment instrument risk factor 9, which concerns the “Number and Nature of Prior Crimes,” for his prior New Jersey conviction for lewdness. The court of appeals determined that reliance on the underlying conduct of a prior foreign conviction is appropriate as a matter of law for purposes of assessing points under risk factor 9 and that the New York Board of Examiners of Sex Offenders and courts should apply the “essential elements” test set forth in In re North v. Bd. of Exam'rs of Sex Offenders of State of N.Y., 871 N.E.2d 1133 (N.Y. 2007) when considering whether to assess points for the prior foreign conviction. Under that test, Defendant’s New Jersey conviction was comparable to the New York offense of endangering the welfare of a child. It was therefore proper to assess him 30 points for his prior criminal history. The Court of Appeals also held that the New York Board of Examiners of Sex Offenders may rely on youthful offender adjudications and juvenile delinquency findings as "reliable indicators of wrongdoing" in connection with assessing "an offender's likelihood of re-offense and danger to public safety," even though they are not technically criminal convictions.

Summary of Case Context & HoldingPinkney was charged with five felony counts of election forgery under MCL 168.937 and six misdemeanor counts of making a false statement in a certificate-of-recall petition under MCL 168.957 for having submitted petitions with falsified dates in connection with an effort to recall the mayor of Benton Harbor. The issue was whether a defendant could be convicted of election-law forgery under MCL 168.937, which provides for fine or imprisonment if a person is found guilty of forgery, generally. The Supreme Court held that MCL 168.937 did nothing more than provide the punishment for the already-committed offense of election-law forgery, and did not create a chargeable offense. The Supreme Court reasoned that there was no evidence that the Legislature intended to incorporate the common-law definition of forgery, that the statutory history of the Election Law provided further support for the conclusion that the statute was a penalty provision, that construing MCL 168.937 as creating the separate, substantive offense of forgery would render the other relevant statutes surplusage. The defendant was not properly charged with the substantive offense of election-law forgery, and the judgment was reversed and remanded to the trial court.

Summary of Case Context & HoldingThe Supreme Court considered the de novo legal issue of whether a guilty plea prevents a defendant from asserting an actual innocence claim under Illinois’ Post-Conviction Hearing Act. Defendant was charged in 2014 with armed violence, unlawful possession of a weapon by a felon, unlawful possession of a controlled substance, and unlawful possession of a controlled substance with intent to deliver. Defendant accepted a plea agreement and knowingly and voluntarily plead guilty to one count of armed violence in exchange for a sentence of 15 years imprisonment. Defendant subsequently filed a post-conviction petition attaching an affidavit from Davie Callaway to support a claim of actual innocence with respect to possession of the cocaine and firearm, in which Callaway stated that he was the sole owner of the cocaine and that Defendant had no knowledge of its presence. The appellate court looked to People v. Cannon, 263 N.E.2d 45 (Ill. 1970), but the Supreme Court noted that the relevant statements from Cannon, in which the court found claims that were included in a defendant's petition but not subsequently argued upon appeal to lack merit, were merely dicta. The Supreme Court held that a guilty plea does not bar a defendant from asserting an actual innocence claim under Illinois’ Post-Conviction Hearing Act, though the defendant must provide new, material, noncumulative evidence that clearly and convincingly demonstrates that a new trial would probably result in acquittal. Because it was not unreasonable for the Court to question Callaway’s truthfulness under the circumstances of Defendant’s case, in which Callaway only came forward after discussing the case with Defendant in prison and had expressed feeling bad for Defendant, the Supreme Court affirmed the denial of Defendant’s petition in his specific case.