Illinois Supreme and Appellate Court Case Summaries

By Laurence J. Dunford (LJD), Robert Clifford( RJC)  and Timothy J. Joyce(TJJ)

 

This page contains the current month's summaries, the most recent summaries provided first. 

Click on the case-name link to go directly to the full-text opinion.

Summary headings and authoring Justice (and separate opinion writers) in GREEN.

Case-name link in your browser's LINK COLOR.

Corrected or modified opinions noted by PURPLE headings.


For the previous six months' summaries or to return to the Illinois Court Reports Home Page, click on the link below:

 Illinois Court Reports Home Page  

 Printer Friendly Version


12 Appellate Cases Posted 11-30-12

1. Criminal Law: Affirmed in part and remanded in part: Legislation enacted subsequent to Supreme Court decision in People v. Hauschild did not revive 15-year enhancement for armed robbery committed with a firearm, thus requiring that defendant be granted a new sentencing hearing on armed robbery conviction, and one conviction for aggravated unlawful use of weapon vacated per "one act, one crime" rule. Steel, J. (Sterba, J., dissenting in part).

No. 2012 IL App (1st) 102939  People v. McFadden  Filed 11-30-12 (TJJ)


Following a bench trial in the circuit court of Cook County, the trial judge found defendant Onaffia McFadden guilty of three armed robberies while armed with a firearm and two counts of unlawful possession or use of a weapon by a felon (720 ILCS  5/24-1.1(a) (West 2008)). The trial judge sentenced McFadden to 29 years in prison on each of the armed robbery convictions, including a 15-year enhancement for carrying a firearm pursuant to section 18-2(b) of the Criminal Code. The trial judge also  sentenced McFadden to 10 years in prison on each of the convictions for UUW by a felon. All of the sentences were ordered to be served concurrently. On appeal, McFadden contends that: (1) the 15-year statutory enhancement of his armed robbery  sentences is unconstitutional; (2) his sentence is otherwise excessive; (3) one of his convictions for UUW by a felon violates the "one-act, one-crime" rule; and (4) the mittimus must be corrected to remove an erroneous conviction for aggravated unlawful  use of a weapon (AUUW). For the following reasons, we agree with McFadden's first, third and fourth claims, vacate the armed robbery sentences, vacate one of his convictions for UUW by a felon, correct the mittimus, and remand the case for  resentencing.

2. Criminal Law: Sentence vacated, remanded for resentencing: Mandatory natural life sentence for 17-year-old defendant deemed accountable in double murder case vacated pursuant to United States Supreme Court case in Miller v. Alabama, which is properly given retroactive effect. Salone, J. (Sterba, J., sp. conc.).

No. 2012 IL App (1st) 103568  People v. Morfin  Filed 11-30-12 (TJJ)


Defendant Nicholas Morfin appeals from an order of the circuit court dismissing his second or successive petition for relief from judgment challenging his mandatory sentence of natural life imprisonment for two counts of first degree murder on the basis  that he was a minor at the time of his offenses. Defendant contends that a mandatory life sentence for an offender under 18 years old violates the Illinois constitutional requirement of proportionate penalties and the federal constitutional prohibition against  cruel and unusual punishments. In particular, he contends that his claim is meritorious under the United States Supreme Court decision in Miller v. Alabama, __ U.S. __, 132 S. Ct. 2455 (2012). The State responds that defendant's constitutional challenges  to his sentence are barred as res judicata and are not meritorious, and particularly contends that Miller does not apply herein as it is a new rule of law that cannot be applied retroactively on collateral review. For the reasons stated below, we agree with defendant, vacate his sentence, and remand for resentencing consistent with Miller.

3. Public Utilities: Affirmed: Illinois Commerce Commission decision granting electrical utility a certificate of pubic convenience and necessity for construction of a power line on petitioners' property upheld over claim that other routes were superior. Birkett, J.

No. 2012 IL App (2d) 110619  Kreutzer v. Illinois Commerce Comm'n  Filed 11-30-12 (TJJ)


This case comes before this court for the second time. In the prior proceeding, Kreutzer v. Illinois Commerce Comm’n, 404 Ill. App. 3d 791, 815 (2010) (Kreutzer I), we reversed the order of the Illinois Commerce Commission granting respondent  Commonwealth Edison Co. a certificate of public convenience and necessity for the construction of an electrical power line along Kreutzer Road, on which is situated the property of petitioners, Frances Kreutzer, Marie Caranci, William Byrne, and Linda Byrne. On remand, ComEd modified the dimensions of the easement it was seeking and the Commission determined that this change cured the evidentiary deficiency on which the reversal in Kreutzer I was based. The Commission rejected petitioners’  attempt to introduce additional evidence on whether the Kreutzer Road route was superior to the other candidate routes, an issue that the Commission had determined in the first proceeding. The Commission reasoned that our reversal and remand in  Kreutzer I was narrow and did not reopen the issue that petitioners attempted to reargue. The Commission reconfirmed the Kreutzer Road route with the modification that ComEd had made. Petitioners appeal, and we affirm.

4. Public Employee Law: Affirmed: Illinois Labor Relations Board decision that three supervisory employees were certified as union as bargaining representative for them was not clearly erroneous and was affirmed. Appleton, J. (Cook, dissenting).

No. 2012 IL App (4th) 110209  Department of Central Management Services v. Illinois Labor Relations Board  Filed 11-30-12 (TJJ)


On September 9, 2008, the American Federation of State, County and Municipal Employees, Council 31 (union), filed with the Illinois Labor Relations Board, State Panel (Board), a majority-interest petition to represent three regional supervisors employed  by the Illinois Department of Public Health (Department) in the job title or classification of senior public administrator, option 8H. On September 7, 2010, after an administrative hearing conducted on February 2, 2010, the administrative law  judge (ALJ), Sylvia Rios, issued a recommended decision and order granting the petition. On January 28, 2011, the Board decided the ALJ was correct and ordered the Board's Executive Director, John Brosnan, to certify the union as the exclusive representative of the three petitioned-for regional supervisors. On February 3, 2011, Brosnan issued  a certification of representation, stating that the three senior public administrators, option 8H, were within the existing bargaining unit designated as  RC-63. The Department appeals on the ground that the petitioned-for individuals were supervisory employees within the meaning of section 3(r) of the Illinois Public Labor Relations Act. We find no clear error in the Board's decision that the individuals at  issue were "employees" with the right to bargain collectively. Therefore, we affirm the Board's decision.

5. Negligence Law: Reversed and remanded: Trial court ruling prohibiting plaintiff in personal injury case stemming from auto accident from eliciting evidence of his statement to insurance investigator as to plaintiff's complaint of pain erroneous, where claim of complaint was relevant to show plaint's purported injuries and investigator's status with insurance company could have been avoided. Cook, J.

No. 2012 IL App (4th) 120031  Cundiff v. Patel   Filed 11-30-12 (TJJ)


In March 2009, plaintiff, Bradley Cundiff, sued defendant, Gunvant Patel, for negligence. In July 2010, defendant filed a motion in limine barring evidence relating to conversations between plaintiff and defendant's liability insurance provider. The trial  court granted the motion. In September 2011, a jury returned a verdict in favor of plaintiff for $3,054. Plaintiff appeals, arguing the trial court erred by granting defendant's motion in limine barring evidence of a conversation between plaintiff and  defendant's liability insurance provider. We reverse.

6. Domestic Relations: Reversed and remanded: Trial court order granting father unsupervised visitation reversed as not in best interest of child, in light of child's tender age (16 months) and sporadic prior contact; trial court should have applied best interests standard in Section 602 of Marriage Act, rather than "endanger seriously" standard of Section 607. Also error to modify order of protection to permit contact with mother to facilitate visitation in light of violent history of parents' relationship. Cook, J.

No. 2012 IL App (4th) 120525  Wittendorf v. Worthington  Filed 11-30-12 (TJJ)


Petitioner, Geannette Wittendorf, and respondent, Kenneth Worthington, are the biological parents of L.W, born September 19, 2010. The parties were never married. On April 20, 2012, the trial court awarded Geannette residential custody of L.W. and  Kenneth unsupervised visitation. The court also modified Geannette’s order of protection against Kenneth to allow for personal, mail, and telephonic contact to the extent that it is strictly necessary to effectuate the terms of the visitation order. On April 20,  2012, Geannette filed a motion for rehearing. On May 18, 2012, after a hearing on the motion, the court affirmed its decision as to visitation and modification of the order of protection. Geannette appeals, and we reverse and remand as to visitation and  affirm the court’s modification of the order of protection.

7. Criminal Law: Reversed and remanded: Trial court erred in dismissing post-conviction petition at second stage of proceedings where defendant alleged ineffective assistance of counsel based upon a per se conflict of interest stemming from counsel's prior representation of murder victim and counsel's alleged failure to call alibi witnesses on defendant's behalf. Garcia, J.

No. 2012 IL App 101631  People v. Cleveland  Filed 11-30-12 (TJJ)


The trial court dismissed defendant Albert Cleveland's petition at the second stage of postconviction proceedings. In 1996, the defendant was convicted of murder and attempted murder. In 1998, the defendant filed a pro se postconviction petition alleging  ineffective assistance of trial counsel based on a per se conflict of interest and counsel's failure to call the mother of his children as an alibi witness. Over the course of 10 years, appointed counsel supplemented the defendant's initial petition with additional  affidavits from other potential exculpatory witnesses and added another claim of ineffective assistance of counsel alleging he was precluded from testifying by his defense counsel. We conclude the defendant has made a substantial showing of a  constitutional violation based on counsel's failure to interview several alibi witnesses. We affirm the dismissal of the defendant's final claim based on counsel's alleged refusal to allow him to testify because the defendant did not assert his desire to testify  before the trial court. We remand for a third-stage evidentiary hearing on the claims that his counsel was subject to a per se conflict of interest and that defense counsel failed to call known exculpatory witnesses.

8. Criminal Law: Affirmed: Defendant proved guilty of predatory criminal sexual assault beyond a reasonable doubt despite claim that minor victim's testimony was inconsistent; victim's out-of-court statements properly admitted pursuant to Section 115-10 of Code of Criminal Procedure; medical doctor's expert opinion testimony properly admitted; and defendant not entitled to a fitness hearing where defense counsel, but not trial court, expressed a doubt as to defendant's fitness. Gordon, J.

No. 2012 IL App (1st) 103590  People v. Garcia  Filed 11-30-12 (TJJ)


After a jury trial, defendant Baldomero Garcia was convicted of two counts of predatory criminal sexual assault and sentenced to two eight-year consecutive sentences in the Illinois Department of Corrections for his conduct toward L.P. (the victim), the  five-year-old daughter of defendant’s live-in girlfriend. On appeal, defendant argues: (1) the State did not prove him guilty beyond a reasonable doubt, (2) the trial court erred by admitting the victim’s out-of-court statements into evidence, (3) the trial court  erred by permitting the State’s expert to testify to a medical opinion for which there was no foundation, and (4) defendant’s due process rights were violated when he did not receive a fitness hearing and no independent judicial determination of defendant’s  fitness was made. For the reasons that follow, we affirm.

9. Administrative Review/Horse Racing: Affirmed: Trial court properly upheld Racing Board decision that percentage of funds paid by riverboat casinos for distribution to holders of horse racing licenses would be distributed at same percentages as those extant in 2006 statute. Lampkin, J.

No. 2012 IL App (1st) 111780  Hawthorne Race Course, Inc. v. Illinois Racing Board  Filed 11-30-12 (TJJ)


Plaintiff, Hawthorne Race Course, Inc. (Hawthorne), appeals the circuit court's ruling upholding the decision of defendant, the Illinois Racing Board (Board), in interpreting the Illinois Horse Racing Act of 1975 (Racing Act) (230 ILCS 5/54.75 (West   2010)). Plaintiff contends the Board erred in concluding that the percentage of the Horse Racing Equity Trust Fund (Fund) payable to each eligible licensee under the 2008 version of the Racing Act should be the same as that previously distributed under  the 2006 version of the statute. Based on the following, we affirm.

10. Public Pension Law: Reversed and remanded: Trial court erred in dismissing Attorney General action contesting police pension board from continuing to pay pension to retired officer convicted of obstruction of justice, as Attorney General's authority to bring action under Pension Code rather than Administrative Review Act, and pension board 4-4 vote on issue of continuing payments begun previously to conviction prohibited pension board from continuing pension payments. Hall, J. (Garcia, J., sp. concurring).

No. 2012 IL App (1st) 112842  People v. Burge  Filed 11-30-12 (TJJ)


The Illinois Attorney General appeals from an order of the circuit court dismissing her complaint against defendants-appellees the Retirement Board of the Policemen's Annuity and Benefit Fund of the City of Chicago, its board of trustees (Pension Board),  and Jon Burge, a retired Chicago police officer. In the complaint, the Attorney General, acting on behalf of the People of the State of Illinois, sought declaratory and injunctive relief seeking to enjoin the Pension Board from making ongoing pension  payments to Burge in light of his felony convictions. For the reasons that follow, we reverse and remand the matter to the circuit court for further proceedings.

11. Condominium Law: Affirmed in part and reversed in part: Trial court properly dismissed plaintiff's claims for constructive fraud and intentional and negligent infliction of emotional distress in connection with claim that condominium board failed to act to prevent damage to plaintiff's unit, but improperly dismissed claim that defendant board breached its fiduciary duties to plaintiff, where plaintiff claimed that board failed to manage properly common ground elements of building. Lampkin, J.

No. 2012 IL App (1st) 113577  Duffy v. Orlan Brook Condominium Owners' Association  Filed 11-30-12 (TJJ)


Plaintiff, Norma Duffy, appeals the circuit court’s order granting the dismissal of her fourth amended complaint in favor of defendants, Orlan Brook Condominium Owners’ Association (condo association) and unknown members of the Orlan Brook  Condominium Owners’ Association, individually (board members). Plaintiff contends her fourth amended complaint adequately pled causes of action for breach of fiduciary duty, constructive fraud, intentional infliction of emotional distress, and, in the alternative, negligent infliction of emotional distress. Based on the following, we affirm in part, reverse in part, and remand for further proceedings.

12. Landlord-Tenant Law: Under commercial lease which made provision for tenant to pay certain amounts in connection with improvement to HVAC at building, subsequent sale of building by landlord did not abrogate tenant's responsibility to pay; landlord had standing to maintain action after sale of building, and trial court order dismissing landlord's claim was error. Gordon, J.

No. 2012 IL App (1st) 121183  A.M. Realty Western L.L.C. v. MSMC Realty, L.L.C.  Filed 11-30-12 (TJJ)


Plaintiff A.M. Realty Western L.L.C. (AM Realty) sued a former tenant, defendant MSMC Realty, L.L.C. (MSMC), to collect monthly payments that the former tenant had agreed to pay, in addition to rent, for certain building improvements. Defendant  moved to dismiss on the ground that plaintiff no longer had standing to collect under the prior lease because plaintiff had since sold the building. On November 17, 2011, the trial court granted defendant's motion and dismissed the complaint with prejudice.  For the following reasons, we reverse.


2 Appellate Cases Posted 11-29-12

1. Criminal Law: Affirmed and modified: Numerous fines and fees to be imposed (or not imposed) upon conviction for aggravated driving under the influence of alcohol discussed and cited, together with the appellate court's admonition for the need for appropriate computer software to be used so as to more efficiently and accurately impose authorized mandatory fines upon conviction. Pope, J.

No. 2012 IL App (4th) 110018  People v. O'Laughlin Filed 11-29-12 (TJJ)


Defendant, Robert E.D. O'Laughlin, argues the Macon County circuit clerk improperly imposed various fines against him as a result of his convictions for aggravated driving under the influence of alcohol, driving while license revoked or suspended, and aggravated fleeing or attempting to elude an officer. The State concedes the circuit clerk erred in imposing certain fines. However, the State asks this court to remand the case to the trial court for it to impose certain mandatory fines. We affirm defendant’s  conviction, vacate the fines improperly imposed by the circuit clerk, and remand this case with directions for the trial court to impose certain fines as directed and others if deemed appropriate.

2. Criminal Law: Affirmed and modified: One of two aggravated battery convictions ordered vacated pursuant to the "one act, one crime" rule, but matter remanded for trial court to determine which of two Class 3 felonies was "less serious" and to vacate that conviction; one fine vacated and one fine reduced. Cook, J.

No. 2012 IL App (4th) 110668  People v. Millsap  Filed 11-29-12 (TJJ)


On October 8, 2010, defendant, Adam J. Millsap, was charged in a three-count information with aggravated battery. After a bench trial, he was convicted of two counts of aggravated battery and sentenced to serve concurrent terms of four years in the  Illinois Department of Corrections. The trial court also ordered defendant to pay various assessments including a Violent Crime Victims Assistance Fund (VCVA) assessment and a Children's Advocacy Center (CAC) assessment. On appeal, defendant  argues that (1) under the one-act, one-crime rule, one of his convictions for aggravated battery must be vacated; (2) the $40 CAC assessment should be reduced; and (3) the $25 VCVA assessment should be reduced to $4. We affirm as modified and remand with directions.

4 Appellate Cases Posted 11-28-12

1.  Employment/Drug Testing/Admin. Review: Affirmed:  No showing that the print-out had the reliability necessary to allow it to support proffered opinions. Because the lab report was not shown to be reliable, and because witness himself admittedly had no involvement in testing the plaintiff's sample, the Board failed to lay a proper foundation for that testimony. Witness conclusions were therefore inadmissible. Without that testimony, which formed the crux of the Board's case against the plaintiff, the Board lacked sufficient evidence to justify the plaintiff's termination. Hoffman, J.  

No. 2012 IL App (1st) 112655   Promisco v. Dart   Filed 11-28-12 (RJC)           


The Sheriff of Cook County, Thomas J. Dart (Sheriff), filed charges with the Cook County Sheriff's Merit Board (Board) seeking to discharge the plaintiff, Kenneth Promisco, from his employment as a lieutenant in the Sheriff's Court Services Department for violating, inter alia, the Sheriff's Drug-Free Work Policy (Drug Policy). Following a hearing, the Board found that the plaintiff had violated the Drug Policy and ordered his discharge. On administrative review of the Board's decision, the Circuit Court of Cook County entered an order setting aside the Board's decision and ordering the plaintiff reinstated to his prior position of employment with full back pay and benefits. The Sheriff, the Board, and the members of the Board have appealed the circuit court's order, and, for the reasons which follow, we affirm the judgment of the circuit court.

2.  Probate/Guardianship: Reversed in part and vacated in part; cause remanded with directions: The order was not preceded by any finding regarding Maria’s standing to proceed on the first petition. While the court addressed the standing issue with respect to the second petition, the court failed to make any finding pertaining to the child’s best interest. Therefore, the court’s March 2, 2012, order granting the second petition for guardianship under the Probate Act, is vacated pending a best interest determination. Wright, J.  

No. 2012 IL App (3d) 120475   In re Estate of H.B.    Filed 11-28-12 (RJC)


Courtney B. (Courtney), mother of the minor H.B., appeals the trial court’s order of November 19, 2010, awarding “temporary” guardianship of H.B. to Maria B. (Maria), H.B.’s maternal grandmother, without Courtney’s consent, pursuant to the Probate Act of 1975 (755 ILCS 5/1-1 et seq. (West 2010)) (the Probate Act). She also appeals the order of March 2, 2012, granting the maternal grandparents, Maria and Darrell B. (Darrell), joint guardianship of H.B. over Courtney’s objection, also under the Probate Act. Reversal of the 2010 order, vacate the 2012 order, and remand the case for further findings based on the evidence presented.

3.  Criminal Law: Affirmed:  "Constructive possession may be inferred from the facts, but evidence establishing constructive possession is often entirely circumstantial." As noted by the trial court, it is incredible to believe defendant's argument that for no reason he helped drive a car across the country for delivery to an unidentified Cuban. Viewing the evidence in the light most favorable to the prosecution, a rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt.  The trial court found that P.O. Owen was gathering information for the warning tickets, and this did not prolong the stop, especially considering the language barrier increasing the difficulty of communication between the men. He  did not have to call for a drug-sniffing dog. The dog was already there.  The Department of Corrections' 2011 financial impact statement was issued in compliance with section 5-4-1. The trial court did not err in sentencing defendant. Cook, J.  

No. 2012 IL App (4th) 110720    People v. Canizalez-Cardena     Filed 11-28-12 (RJC)   


Defendant Jose Canizalez-Cardena (hereinafter Cardena) was charged with unlawful possession with intent to deliver methamphetamine, a Class X felony, in that he knowingly and unlawfully possessed with intent to deliver 900 grams or more of a substance containing methamphetamine. 720 ILCS 646/55(a)(1), (2)(F) (West 2010). Cardena was convicted after a stipulated bench trial and sentenced to 25 years in prison on July 25, 2011. His timely motion to reconsider sentence was denied August 10, 2011, and notice of appeal was timely filed August 12, 2011. The appeal argues three issues: that the evidence was insufficient to convict, that a motion to suppress evidence was improperly denied, and that the trial court considered improper factors in sentencing. Affirmed.

4. Parental Rights/Fitness:  Reversed and remanded:  Under the facts of this case, it is illogical to believe that Julia suffered from a mental impairment severe enough to render her incapable of discharging her parental responsibilities for S.L., but that, at the same time, she was capable of discharging her parental responsibilities for M.P.  Since there is no other evidence of the first element of this statutory ground for unfitness, the trial court's finding that the State proved the first element of section 1(D)(p) is against the manifest weight of the evidence. The State's failure to prove the first element of the statute is fatal to a finding of unfitness on this ground because proof by clear and convincing evidence of both elements is necessary. The only basis for the trial court's finding of unfitness on the second element of section 1(D)(p) is testimony that Julia would need six months to a year of  "logistical stability" to demonstrate that she had made sufficient changes to enable her to regain custody of S.L. However, at the time of the hearing, Julia had demonstrated every element of the "logistical stability" that witness found essential. Thus, the trial court's finding that the State proved the allegation of unfitness pursuant to section 1(D)(p) of the Adoption Act is against the manifest weight of the evidence and must be reversed. Stewart, J.  

No. 2012 IL App (5th) 120271    In re S.L.     Filed 11-28-12 (RJC)


On January 18, 2011, the State filed a petition for termination of the parental rights of Bruce V. and Julia F., the parents of S.L., a minor child. The father did not participate in the proceedings below and has not filed a brief in this court.  After an evidentiary hearing, the trial court entered an order finding that the State had not proved the first two grounds but had proved Julia to be unfit under the final two grounds alleged in the amended petition. Julia appeals from the order of the circuit court of Marion County finding her to be an unfit parent under sections 1(D)(m)(iii) and 1(D)(p) of the Adoption Act (750 ILCS 50/1(D)(m)(iii), (D)(p) (West 2010)). We reverse and remand.       
 

3 Appellate Cases Posted 11-27-12

1.  Criminal Law\Post-Conviction Petitions: Reversed and cause remanded:  Two questions are presented. First, whether the denial of defendant Carl Williams' petition for an evidentiary hearing to show actual innocence should be reversed. Second, whether the United States Supreme Court's holding in Miller v. Alabama, 567 U.S. __ , 132 S. Ct. 2455 (2012), prohibiting mandatory life-without-parole sentences for juveniles should be retroactively applied.  The answer to both is yes.  Defendant has satisfied the cause-and-prejudice test of section 122-
1(f) of the Act and the circuit court erred in denying his motion for leave to file a successive postconviction petition.  Defendant has satisfied the cause element of the cause-and-prejudice test, but he still must show that he was prejudiced. Defendant can show prejudice if the Supreme Court's decision in Miller applies retroactively to his case. The Miller case held under the eighth amendment that it is cruel and unusual punishment to impose a mandatory life sentence without parole to a special class – juveniles. It would also be cruel and unusual to apply that principle only to new cases.  Miller should be retroactively applied. Harris, J.

No. 2012 IL App (1st) 111145    People v. Williams     Filed 11-27-12 (RJC)   


Defendant appeals the dismissal of two of his successive petitions (third and fourth petitions) for relief under the Post-Conviction Hearing Act (Act) (725 ILCS 5/122-1 et seq. (West 2010)). In his third petition, which the circuit court reviewed as a second-stage proceeding under the Act, defendant made a claim of actual innocence, and claimed that the State withheld exculpatory evidence in violation of Brady v. Maryland, 373 U.S. 83 (1963), and that he was arrested without probable cause. The circuit court granted the State's motion to Nos. 1-11-1145 and 1-11-2251 (Consolidated) dismiss his third petition. In his motion for leave to file his fourth petition, defendant alleged that his mandatory life sentence is unconstitutional. The circuit court denied him leave to file his fourth petition. At issue is whether defendant has made a substantial showing that his constitutional rights have been violated such that he is entitled to an evidentiary hearing on his claims in his third petition; and whether defendant has satisfied the cause-and-prejudice requirements codified under section 122-1(f) of the Act such that the circuit court erred in denying his motion for leave to file his fourth petition challenging his sentence.

2.  Criminal Law\Post-Conviction Petitions: Affirmed:  Contentions by defendant fail to present a meritorious basis for a section 2-1401 petition for relief from judgment or a postconviction petition: (1) he was not properly admonished about MSR; (2) he is entitled to the "benefit of the bargain" as in People v. Whitfield, 217 Ill. 2d 177, 840 N.E.2d 658 (2005); (3) imposition of MSR violates the United States and Illinois Constitutions; (4) application of MSR is an unlawful constraint upon defendant's liberty; and (5) the MSR system violates the doctrine of separation of powers. Cook, J. with special concurrence by Turner, J. 

No. 2012 IL App (4th) 110403    People v. Lee    Filed 11-27-12 (RJC)        


This appeal comes to us on the motion of the office of the State Appellate Defender (OSAD) to withdraw as counsel on appeal on the ground no meritorious issues can be raised in this case.

3.  Criminal Law: Affirmed: The trial court never questioned whether defendant was consciously engaged in his trial and sentencing—defendant's awareness of the nature of the proceedings was evident in his participation in them.  Notwithstanding that the defendant was being held in the prison's mental health unit and being treated for schizophrenia, no bona fide doubt of the defendant's fitness requiring reversal of his conviction arose during these proceedings.  The evidence in this case permitted the inference that the contact was of an insulting or provoking nature. Cook, J.

No. 2012 IL App (4th) 110519     People v. Nichols     Filed 11-27-12 (RJC)          


In March 2011, a jury found defendant, Demetrius Nichols, guilty of aggravated battery. In June 2011, the trial court sentenced defendant to seven years in prison, to be served consecutively to sentences defendant was already serving. Defendant appeals, arguing (1) the trial court erred by not ordering a fitness hearing on its own motion in response to allegedly incoherent and delusional statements defendant made and his treatment during these proceedings for schizophrenia and (2) the State failed to prove him guilty of aggravated battery beyond a reasonable doubt.  Affirmed.


11 Supreme Court Cases Posted 11-29-12

1.  Criminal Law: Appellate And Trial Court Affirmed:    Under the plain-error rule, codified in Supreme Court Rule 615, “[a]ny error, defect, irregularity, or variance which does not affect substantial rights shall be disregarded” unless the appellant demonstrates plain error.  If a defendant fails to make a plain-error argument, we generally honor his procedural default, because a defendant who fails to argue for plain-error review when he has forfeited review of an issue “obviously cannot meet his burden of persuasion” that one of the two prongs of the plain-error rule is satisfied.   Resolution of a claim under Crawford requires a court to answer a series of questions: (1) Was the out-of-court statement hearsay because it was offered by for the truth of the matters asserted therein? (2) If hearsay, was the statement admissible under an  exception to the hearsay rule? (3) If admissible hearsay, was the statement testimonial in nature? and (4) If testimonial, was admission of the statement reversible error?  The autopsy report could have been admitted under exceptions to hearsay rules.  Rule 803(6) applies to records of regularly conducted activities if kept in the normal course of business, “but not including in criminal cases medical records.”   Rule 803(8) codifies the long-standing hearsay exception for records “of public offices or agencies, setting forth *** matters observed  pursuant to duty imposed by law as to which matters there was a duty to report, excluding, however, police accident reports and in criminal cases medical records and matters observed by police officers and other law enforcement personnel.”  Both rules apply unless the sources of information or the method or circumstances of preparation of the record indicate a lack of trustworthiness.  We conclude that whichever definition of primary purpose is applied, the autopsy report in the present case was not testimonial because it was (1) not prepared for the primary purpose of accusing a targeted individual or (2) for the primary purpose of providing evidence in a criminal case.  Garman, J., Kilbride, CJ., dissents

No. 2012 IL 111534   People v. Leach    Filed 11-29-12 (LJD)


Defendant Curtis Leach was convicted after a bench trial in the circuit court of Cook County of the first degree murder (720 ILCS 5/9-1(a)(2) (West 2002)) of his wife, Latyonia Cook-Leach, and sentenced to 28 years’ imprisonment. His conviction and sentence were affirmed on appeal. People v. Leach, 391 Ill. App. 3d 161 (2009). Upon defendant’s initial appeal to this court, we vacated the appellate court’s judgment and remanded the cause to that court for consideration in light of People v. Williams, 238 Ill. 2d 135 (2010). People v. Leach, 237 Ill. 2d 575 (2010)  supervisory order). After reconsideration, the appellate court again affirmed defendant’s conviction. 405 Ill. App. 3d 297. We then allowed defendant’s petition for leave to appeal under Supreme Court Rule 315 (Ill. S. Ct. R. 315 (eff. Feb. 26, 2010)). We are asked to determine whether admission of the opinion testimony of a pathologist other than the pathologist who performed the autopsy on the victim and of the autopsy report itself violated the rule of Crawford v. Washington, 541 U.S. 36 (2004).

2.  Post conviction Petitions: Appellate and Trial Court Reversed and cause remanded:  Three stages of post conviction petitions are enumerated and discussed.  A first-stage postconviction petition prepared by an attorney would NOT essentially be required to make a substantial showing of a constitutional violation, which is the standard at the second stage, after the State has entered the litigation.   At the first stage of postconviction proceedings under the Act, a petition alleging ineffective assistance may not be summarily dismissed if (i) it is arguable that counsel’s performance fell below an objective standard of reasonableness and (ii) it is arguable that the defendant was prejudiced.    Freeman, J.

No. 2012 IL 112214   People v. Tate   Filed 11-29-12 (LJD)


  Petitioner, Douglas Tate, filed a postconviction petition in the circuit court of Cook County. The appellate court affirmed the circuit court’s summary dismissal. No. 1-09-2379 (unpublished order under Supreme Court Rule 23). We granted leave to appeal, and now reverse the judgment of  the appellate court and remand to the circuit court for further proceedings.

3.  Sexually Violent Persons Act: Affirmed in Part and Reversed in Part:  Definitions of a  “sexually violent person” and 'mental disorder" set out.  If the State proves beyond a reasonable doubt that an individual is a sexually violent person, that individual may be indefinitely committed “until such time as the person is no longer a sexually violent person.”  Periodic examinations are required. The stated purpose of these periodic examinations is to determine “whether the person has made sufficient progress to be conditionally released or discharged.”   A committed person may seek a discharge under three available mechanisms, which are listed and discussed.   The quantum of evidence needed to support a finding of probable cause to believe that a person is a sexually violent person under the Act is “probable cause” using its ordinary and popularly understood meaning.   “[T]he hearing is intended to be preliminary in nature, a ‘summary proceeding to determine essential or basic facts as to probability’ *** remaining cognizant of the respondent’s liberty rights.”   The judge should not weigh conflicting evidence and choose between expert opinions at this “summary proceeding” to determine probable cause.   Scope of the probable cause hearing also discussed. Theis, J.

No. 2012 IL 112337  In re Detention of Stanbridge  Filed 11-29-12 (LJD)


In these consolidated appeals, we are asked to clarify the quantum and scope of evidence needed to establish probable cause in a postcommitment discharge or conditional release proceeding pursuant to the Sexually Violent Persons Commitment Act (725 ILCS 207/1 et seq. (West 2008)). In  both cases, the trial court found a lack of probable cause and dismissed the individual petitions for discharge or conditional release. In Stanbridge, the appellate court reversed, finding that the trial court improperly weighed contradictory evidence of the parties’ respective experts. Stanbridge,  08 Ill. App. 3d 553. In Lieberman, the appellate court affirmed, over a dissent, finding that the expert did not present sufficient evidence on the relevant statutory elements to warrant a further hearing and did not comply with the statutory requirements for conditional discharge. Lieberman,  011 IL App (1st) 090796.  We allowed petitions for leave to appeal in both cases (Ill. S. Ct. R. 315 (eff. Feb. 26, 2010) and consolidated the appeals for review. For the following reasons, we reverse the appellate court judgment in Stanbridge and affirm the appellate court judgment in Lieberman.

4   Criminal Law: Appellate and Trial Court Affirmed:  The Latin term nolle prosequi means “not to wish to prosecute.”   A nolle prosequi may be entered as to an entire charging document, or as to one or more counts.  A nolle prosequi is not an acquittal of the underlying  conduct that served as the basis for the original charge but, rather, it leaves the matter in the same condition as before the prosecution commenced.  We have previously stated that a nolle prosequi order “requires the institution of a new and separate proceeding to prosecute the defendant.”   The entry of the nolle prosequi does not deprive the court of its inherent authority “ ‘to vacate any judgment or order that may have been made at that term.’  A defendant has no absolute right to withdraw his guilty plea.  Rather, he must show a manifest injustice under the facts involved. Theis, J., Dissent by Freeman, J. joined by Burke, J.

No. 2012 IL 112817  People v. Hughes   Filed 11-29-12 (LJD)


Defendant, Jackie Hughes, pleaded guilty to one count of aggravated criminal sexual abuse (720 ILCS 5/12-16 (West 2006)) and was sentenced to 14 years in prison. Defendant appealed from the denial of his motion to withdraw his plea, contending that the circuit court of Lake County  lacked subject matter jurisdiction to entertain a plea to a previously nol-prossed charge, and that his plea was not knowingly and voluntarily made because the court and counsel failed to advise him of the possibility that the State would file a petition for involuntary commitment under the  sexually Violent Persons Commitment Act (725 ILCS 207/1 et seq. (West 2006)). The appellate court affirmed. 2011 IL App (2d) 090992. For the following reasons, we affirm the judgment of the appellate court.

5.  Civil Discovery/Attorney Client Privilege: Appellate and Circuit Court Reversed, Cause Remanded: Where legal advice of any kind is sought from a lawyer in his or her capacity as a lawyer, the communications relating to that purpose, made in confidence by the client, are protected from disclosure by the client or lawyer, unless the protection is waived.   The privilege is to be strictly confined within its narrowest limits and limited solely to those communications which the claimant either expressly made confidential or which he could reasonably believe under the circumstances would be understood by the attorney as such. The attorney-client privilege belongs to the client, rather than the attorney, although the attorney asserts the privilege on behalf of the client.  Only the client may waive the privilege.  The attorney, although presumed to have authority to waive the privilege on the client’s behalf, may not do so over the client’s objection.  The attorney-client privilege may be waived by the client when the client voluntarily testifies to the privileged matter  or when the client voluntarily injects into the case either a factual or legal issue, the truthful resolution of which requires examination of confidential communications, such as legal malpractice actions. The basic, well-settled rule is that when a client discloses to a third party a privileged communication, that particular communication is no longer privileged and is discoverable or admissible in litigation. This court has held that when a client voluntarily testifies and waives the privilege, such waiver “extends no further than the subject-matter concerning which testimony had been given by the client.”   The purpose behind the doctrine of subject matter waiver is to prevent partial or selective disclosure of favorable material while sequestering the unfavorable.  We hold that subject matter waiver does not apply to the  extrajudicial disclosure of attorney-client communications not thereafter used by the client to gain an adversarial advantage in litigation. Garman, J.

No. 2012 IL 113107  Center Partners, Ltd. v. Growth Head GP, LLC.   Filed 11-29-12 (LJD)


Defendants appeal from a circuit court of Cook County order that granted plaintiffs’ motion to compel the production of certain documents containing privileged attorney-client communications.  Defendants refused to comply with the court’s order to compel production of documents and were found in contempt. Defendants appealed pursuant to Supreme Court Rule 304(b)(5) (eff. Feb. 26, 2010). The appellate court affirmed the granting of the motion to compel. 2011 IL App (1st) 110381.  For the following reasons, we reverse the judgments of the appellate and circuit courts and remand the cause to the circuit court.

6.  Criminal Law: Appellate Court, which reduce crime of defendant, Affirmed: The aggravating circumstances of a threat or an endangerment of the life of the victim must exist during the commission of the offense, that is, while the offender is engaging in the conduct that constitutes the offense. aggravating factor must occur during the offense.  Garman, J.

No. 2012 IL 113116  People v. Giraud   Filed 11-29-12 (LJD)


Defendant was convicted in the circuit court of Cook County of multiple counts, including one count of aggravated criminal sexual assault (720 ILCS 5/12-14(a)(3) (West 2006)). The victim was his teenage daughter. The aggravating factor found by the jury was that “during *** the  commission of the offense,” he “acted in such a manner as to threaten or endanger the life of the victim” (id.), because on at least one occasion, he had forcible intercourse with her without wearing a condom, knowing that he was HIV positive. The appellate court reduced this conviction to criminal sexual assault (720 ILCS 5/12-13 (West 2006)), on the basis that the victim was neither threatened nor her life endangered during the assault. 2011 IL App (1st) 091261, ¶ 30. We allowed the State’s petition for leave to appeal pursuant to Supreme Court Rule 315 (eff. Feb. 26, 2010).

7.   School Funding: Appellate and Trial Court Affirmed: The doctrine of standing insures that issues are raised only by those parties with a real interest in the outcome of the controversy. In order to have standing to challenge the constitutionality of a statute, a party must have sustained, or be in immediate danger of sustaining, a direct injury as a result of the enforcement of the challenged statute.   The claimed injury must be (1) distinct and palpable; (2) fairly traceable to defendant’s actions; and (3) substantially likely to be prevented or redressed by the grant of the requested relief.   Thomas, J. 

No. 2012 IL 113414  Carr et al. v. Koch  Filed 11-29-12 (LJD)


Citizens unhappy with the way in which public school education is funded in Illinois brought this declaratory judgment action against the State Superintendent of Education, the Illinois State Board of Education, and the Governor. The 2010 complaint alleged that a funding system is in place which requires taxpayers in school districts with low property values (such as theirs) to pay property taxes to fund local public schools at a higher rate than similarly situated taxpayers in school districts with higher property values. The complaint alleged that this amounts to a violation of the equal protection clause of the Illinois Constitution of 1970. The circuit court of Sangamon County dismissed the action, and the appellate court affirmed

8.  Farm Nuisance Act: Appellate Court and Trial Reversed: The Doctrine of “coming to the nuisance” refers to those instances where a plaintiff either acquires his land or improves it after the defendant has already begun the nuisance generating activity. At common law, a
plaintiff who came to the nuisance would not be barred from pursuing a nuisance action, but the fact that the land was acquired or improved after the nuisance generating activity began would be a factor in determining whether the nuisance was actionable.   Burke, J.

No. 2012 IL 113569  Toftoy v. Rosenwinkel Filed 11-29-12 (LJD)


At issue in this case is whether the Farm Nuisance Suit Act (740 ILCS 70/1 et seq. (West 2006)) bars the plaintiffs’ nuisance lawsuit against a neighboring cattle farm where the plaintiffs acquired their property after the cattle farm had been in operation for more than a year. The appellate  court  eld that the suit was not barred. 2011 IL App (2d) 100565. For the reasons that follow, we reverse the judgment of the appellate court.

9.  Administrative Review Act/Attorneys Fees: Appellate Court Reversed, Trial Court Affirmed: When “the court” is read together with this phrase 9in Section 10-55(c) of the Act, it becomes clear that the fees are to be awarded by the court that invalidated the rule.  The petition for fees must be brought before the court that invalidated the rule, while it maintains jurisdiction.Garman, J.

No. 2012 IL 113706 Rodriquez v. The Department of Financial and Professional Regulation Filed 11-29-12 (LJD)


Plaintiff, Jack V. Rodriquez, filed a petition with the circuit court  of Cook County seeking reimbursement of litigation expenses pursuant to section 10-55(c) of the Illinois Administrative Procedure Act (5 ILCS 100/10-55 (West 2008)). The petition followed a proceeding where Rodriquez  successfully invalidated an administrative rule of the Department of Financial and Professional Regulations (Department). The circuit court granted the Department’s motion for summary judgment, concluding that Rodriquez’s claim for litigation expenses was barred by res judicata. The  appellate court reversed the circuit court’s finding relating to litigation expenses and remanded the cause to the circuit court for a calculation of reasonable litigation expenses.  For the reasons that follow, we reverse the judgment of the appellate court and reinstate the circuit court’s original judgment.

10.  Juvenile Court/Abuse & Neglect: Appellate Court Affirmed: The State must establish that the allegations of neglect are more probably true than not.  The legislature has stated that the purpose of an adjudicatory hearing is ‘to determine whether the allegations of a petition *** that a minor under 18 years of age is *** neglected *** are supported by a preponderance of the evidence.  Following the adjudicatory hearing, if a trial court determines that a minor is abused, neglected or dependent, the trial court then moves to step two, which is the dispositional hearing.  At the dispositional hearing, the trial court determines whether it is consistent with the health, safety and best interests of the minor and the public that the minor be made a ward of the court.  A neglected minor includes “any minor under 18 years of age whose environment is injurious to his or her  welfare. “Generally, ‘neglect’ is defined as the ‘failure to exercise the care that circumstances justly demand.  Neglect encompasses “wilful as well as unintentional disregard of duty. It is not a term of fixed and measured meaning. It takes its content always from specific circumstances, and its meaning varies as the context of surrounding circumstances changes.  Theis, J.

No. 2012 IL 113875  In re A.P. Filed 11-29-12 (LJD)


This appeal arises from a judgment of the circuit court of Peoria County that found A.P. and J.P. to be neglected minors under section 2-3(1)(b) of the Juvenile Court Act of 1987 (Act) (705 ILCS 405/2- 3(1)(b) (West 2010)) due to an environment injurious to their welfare. At the subsequent  is positional hearing, the circuit court found that respondent-mother Lisa P. was a fit parent and closed the minors’ cases. Respondent appealed, challenging the finding of neglect and the circuit court’s admission of records from the Pediatric Resource Center under section 2-18(4)(a) of the Act 705 ILCS 405/2-18(4)(a) (West 2010)). The appellate court reversed, holding that the circuit court erred in admitting the records and adjudicating the minors neglected. 2012 IL App (3d) 110191. Before this court, the State challenges the appellate court’s determination on both issues. For the reasons that follow, we affirm the judgment of the appellate court reversing the trial court’s determination that the minors’ were neglected.

11.  Mandamus/Sentencing: Writ Awarded: Mandamus is an extraordinary remedy used to compel a public officer to perform nondiscretionary official duties.  We will award mandamus only if the petitioner establishes a clear right to the relief requested, a clear duty of the public officer to act, and clear authority of the public officer to comply with the writ.  Consequently, section 5-8-4(a) must be construed so that any consecutive sentences imposed for triggering offenses be served prior to, and independent of, any sentences imposed for  nontriggering offenses. Sentences for multiple nontriggering offenses may be served concurrently to one another after any consecutive sentences for triggering offenses have been discharged.”  Burke, J.

No. 2012 IL 114163  People v. Meersman Filed 11-29-12 (LJD)


The petitioner, Mark Senko, State’s Attorney of Rock Island County, seeks a writ of mandamus (see Ill. Const. 1970, art. VI, § 4(a)) to compel respondent, the Honorable F. Michael Meersman, judge of the circuit court of Rock Island County, to sentence defendant, Adrian Morrison, in accordance with section 5-8-4(d)(2) of the Unified Code of Corrections (Code) (730 ILCS 5/5-8-4(d)(2) (West 2010)). Petitioner argues that respondent improperly imposed concurrent sentences when consecutive sentences are mandated by the statute. For the following reasons, we award the writ.

3 Appellate Cases Posted 11-27-12

1. Post Conviction Petition:Reversed and Remanded: Only one post conviction petition may be filed.  Res judicata bars issues previously decided on appeal. Id. at 233. Similarly, issues not raised, even though they could have been raised on appeal, are waived.  However, a successive petition will be considered on its merits, and the statutory bar to doing so will be relaxed, in the interest of fundamental In order to have a successive petition considered, a petitioner must satisfy the cause-and-prejudice test, which is set out in the opinion.  A petitioner is excused from the cause-and-prejudice test where petitioner can set forth a claim of actual innocence.  Newly discovered evidence is "evidence that was not available at defendant's original trial and that the defendant could not have discovered sooner through diligence."   "[A]n evidentiary hearing is warranted on a post-conviction claim only where the allegations in the post-conviction petition, supported where appropriate by the trial record or accompanying affidavits, make a substantial showing that the constitutional rights of the defendant have been violated."   The United States Supreme Court did not ban the sentencing of juveniles to life in prison without parole; rather, it held the mandatory sentencing of juveniles to life without parole violates the eighth amendment and required sentencing courts "to take into account how children are different, and how those differences counsel against irrevocably sentencing them to a lifetime in prison."  For a statute  or a sentence to be considered void ab initio under a new constitutional rule, the statute in question has to be rendered facially unconstitutional.   A new rule of criminal procedure applies retroactively in those instances where it has made a substantial or substantive change in the law. (new rules are to be applied retroactively to " 'watershed rules of criminal procedure' " and "limited to those new procedures without which the likelihood of an accurate conviction is seriously diminished" (citing Teague, 489 U.S. at 311)). We find that Miller not only changed procedures, but also made a substantial  change in the law in holding under the eighth amendment that the government cannot constitutionally apply a mandatory sentence of life without parole for homicides committed by juveniles. Life without parole is justified only where the State shows that it is appropriate and fitting regardless of the defendant's age. Harris, J.

No. 2012 IL App (1st) 111145 People v. Williams Filed 11-27-12 (LJD)


We are called upon to determine whether the denial of defendant Carl Williams' petition for an evidentiary hearing to show actual innocence should be reversed. We are also required to determine whether the United States Supreme Court's holding in Miller v. Alabama, 567 U.S. __ , 132 S. Ct. 2455 (2012), prohibiting mandatory life-without-parole sentences for juveniles should be retroactively applied. We answer yes to both issues. 

2. Appellate Procedure: Affirmed:  To be entitled to relief under section 2-1401, the petitioner must set forth specific factual allegations supporting each of the following elements: (1) the existence of a meritorious defense or claim; (2) due diligence in presenting this defense or claim to the circuit court in the original action; and (3) due diligence in filing the section 2-1401 petition.   "[A] postconviction proceeding is a collateral attack upon the prior conviction and affords only limited review of constitutional claims not presented at trial."  Cook, J.,  Turner,  J., Specially concurring.

No. 2012 IL App (4th) 110403 People v. Lee  Filed 11-27-12 (LJD)


This appeal comes to us on the motion of the office of the State Appellate Defender (OSAD) to withdraw as counsel on appeal on the ground no meritorious issues can be raised in this case. For the following reasons, we agree and affirm.

3.  Criminal Law:Affirmed:  Subjecting an unfit defendant to criminal trial violates the defendant's due-process rights. Accordingly, although any party may raise the issue of a defendant's fitness to stand trial at an appropriate time, whenever a bona fide doubt of the defendant's fitness arises, the trial court must sua sponte order a determination of the defendant's fitness before proceeding further.  Where no fitness hearing was held, we will reverse a conviction and remand for a new trial only where the trial court abused its discretion in failing to act on a bona fide doubt of the defendant's fitness.  Cook, J.

No. 2012 IL App (4th) 110519   People v. Nichols   Filed 11-27-12 (LJD)


In March 2011, a jury found defendant, Demetrius Nichols, guilty of aggravated battery. In June 2011, the trial court sentenced defendant to seven years in prison, to be served consecutively to sentences defendant was already serving.  Defendant appeals, arguing (1) the trial court erred by not ordering a fitness hearing on its own motion in response to allegedly incoherent and delusional statements defendant made and his treatment during these proceedings for schizophrenia and (2) the State failed to prove him guilty of aggravated battery beyond a reasonable doubt. We disagree and affirm.

3 Appellate Cases Posted 11-26-12

1.  Criminal Law: Affirmed:  Under the plain-error rule, we may consider a forfeited claim when: “(1) a clear or obvious error occurred and the evidence is so closely balanced that the error alone threatened to tip the scales of justice against the defendant, regardless of the seriousness of the error, or (2) a clear or obvious error occurred and that error is so serious that it affected the fairness of the defendant’s trial and challenged the integrity of the judicial process, regardless of the closeness of the evidence.”  The law on accountability incorporates the “common design rule,” which provides that, where two or more persons engage in a common criminal design, any acts in furtherance thereof committed by one party are considered to be the acts of all parties to the common design and all are equally  responsible for the consequences of such further acts.  Birkett, J.

No. 2012 IL App (2nd) 110082  People v. Czapla  Filed 11-26-12 (LJD)


1 Following a jury trial, defendant, Boguslaw Czapla, was convicted of aggravated battery (720 ILCS 5/12-4(a) (West 2010)) and mob action (720 ILCS 5/25-1(a)(1) (West 2010)). The trial court vacated the mob action conviction and sentenced him to three years’ imprisonment for  aggravated battery. Defendant appeals, contending that the trial court erred by admitting a tape recording of a 911 call that contained a statement by defendant’s brother that defendant committed the offense. We affirm.

2.  Zoning: Affirmed in Part and Reversed in part and Remanded: Under the appropriate circumstances, a claim of proper notice under the Code is a valid basis for a section 2-619 dismissal.   Notice requirements set out in the opinions.  The supreme court held that to satisfy the requirements of procedural due process, the manner of giving notice must be reasonably calculated, under all of the circumstances, to apprise the interested parties of the pendency of the action and afford them an opportunity to present their objections.  Carter, J.

No. 2012 IL App (3rd) 120068  Musicus v. First Equity Group  Filed 11-26-12 (LJD)

Plaintiff, Raphael J. Musicus, brought suit against First Equity Group, LLC (First Equity), CVS Pharmacy, Inc. (CVS), and the City of Kewanee (City) for damages and other relief relating to the City's grant of First Equity's application for rezoning of certain real property and a special use permit. Plaintiff's main allegation in the complaint was that notice of the public hearing on the application was deficient. All three defendants filed motions to dismiss pursuant to section 2-619 of the Code of Civil Procedure (735 ILCS 5/2-619 (West 2010)), alleging that notice was proper.  After a hearing, the trial court granted the motions to dismiss of First Equity and the City (collectively referred to as defendants) and denied the motion to dismiss of CVS. Plaintiff appeals. We affirm the trial court's grant of the City's motion to dismiss and reverse the trial court's grant of First Equity's motion to dismiss.

3.  Domestic Relations: Affirmed:  The rule of forfeiture is a limitation on the parties, not the court.  A reviewing court may override considerations of forfeiture in furtherance of its responsibility to maintain a sound and uniform body of precedent.  A settlement agreement is in the nature of a contract and is governed by principles of contract law.  Oral agreements are binding when there is an offer, an acceptance, and a meeting of the minds as to the terms of the agreement.  For the contract to be enforceable, the material terms must be definite and certain, meaning that the court is enabled from the terms and provisions, under proper rules of construction and applicable principles of equity, to ascertain what the parties have agreed to do. Id.  A meeting of the minds between the parties will occur where there has been assent to the same things in the same sense on all essential terms and conditions.    Stewart, J., Goldenhersh specially concurring

No. 2012 IL App (3rd) 110478  In re Marriage of Haller Filed 11-26-12 (LJD)


On October 19, 2007, Suzie Haller filed a petition for dissolution of marriage from Robert Haller. On March 17, 2011, the parties appeared for trial but reached a settlement agreement, which was read into the record. Both parties testified that it was their desire that the court approve the agreement and that they understood that the agreement was binding. The trial court approved the agreement, entered judgment in a docket entry, and ordered Suzie's attorney to prepare a written judgment to be filed on a later date. Subsequent to the hearing, but before a written judgment was entered, Robert filed a motion to set aside the settlement agreement. Suzie submitted a proposed written judgment and filed a motion for entry of judgment. Following a hearing, the trial court denied Robert's motion to set aside and granted Suzie's motion for entry of judgment.

7 Appellate Cases Posted 11-21-12

1. Criminal Law: Affirmed with correction to mittimus:  Self-defense is an affirmative defense, and once defendant raises it and provides some evidence of it, the State has the burden of proving beyond a reasonable doubt that defendant did not act in self-defense, in addition to the elements of the charged offense.  In Illinois, a person is justified in using deadly force only when he reasonably believes that such force is necessary to prevent imminent death or great bodily harm to himself or another person, or the force threatened is a forcible felony.  Thus, a person acts in self-defense where: (1) force was threatened against defendant; (2) defendant was not the aggressor; (3) the danger of harm was imminent; (4) the force threatened was unlawful; (5) defendant actually believed a danger existed and the use of force was necessary to avert it; and (6) defendant's belief was reasonable. Taylor, J.

No. 2012 IL App (1st) 102089  People v. Lewis  Filed 11-21-12 (LJD)

Following a bench trial, defendant Orlando Lewis was found guilty of the second degree murder of Robert Thompkins and sentenced to eighteen years’ imprisonment. On appeal, defendant contends that the State failed to prove beyond a reasonable doubt that he did not act in self-defense when Thompkins walked toward him after defendant displayed a gun. Defendant further contends that his sentence was  excessive and that his mittimus should be reduced to reflect 1,032 days spent in presentencing custody. The State agrees that his mittimus should be corrected to 1,033 days. As to all other claims, the State disagrees.

2.  Criminal Law: Reversed: A motion to suppress involves mixed questions of law and fact. Because the trial court is in a superior position to determine the credibility of witnesses, findings of historical fact will be upheld on review unless they are against the manifest weight of the evidence.  However, a reviewing court is also free to undertake an independent assessment of the facts in relation to the issues presented.  The ultimate question of whether the evidence should be suppressed is reviewed de novo.  Because warrantless searches are per se unreasonable, if the defendant challenges the warrantless search and demonstrates that he was doing nothing unusual at the time of the search, the State has the burden to demonstrate that the search was legally justified.  Moreover, while an arrest may be based on information of which the arresting officer does not have personal knowledge, when the State attempts to justify a warrantless arrest on that basis, it must establish that the information relied on was based upon facts sufficient to establish probable cause to make an arrest.  Our supreme court have held that while tips, radio bulletins, or official police communications may be relied upon by arresting officers, the State must demonstrate that the information relied upon was sufficient to establish probable cause to arrest the defendant.  Sterba, J.  

No. 2012 IL App (1st) 110966  People v. Hyland  Filed 11-21-12 (LJD)

Following a jury trial, defendant Kraig Hyland was convicted of one count of unlawful use of a weapon by a felon and one count of unlawful possession of a firearm by a street gang member. He was sentenced to concurrent prison terms of three years on each count.  For the reasons that follow, we reverse.

3.  Administrative Review: Affirmed: We review the decision of an administrative agency, not that of the circuit court.  An appellate court should not " 'reweigh evidence or *** make an independent determination of the facts.' "  "However, an administrative agency's conclusions of law *** are reviewed de novo." Once a disability pension is awarded, an annual medical
examination is performed "prior to attainment of age 50 *** to verify continuance of disability." Id. "Upon satisfactory proof to the board that a firefighter on the disability pension has recovered from disability, the board shall terminate the disability pension." The Code expressly provides a process to determine whether a firefighter is fit to be restored to service.   The purpose of the medical examination, which is permitted annually, is to either "verify continuance of disability" or provide "satisfactory proof" that the pensioner has "recovered from disability."  No provision of the Code permits a pension board to revisit and reverse its original decision, made years earlier but never appealed, that a firefighter was rendered disabled by a line-of-duty injury.  Garcia, J., dissent by Gordon, J.

No. 2012 IL App (1st) 112120  Hoffman v. Orland Firefighters' Pension Board Filed 11-21-12 (LJD)

The Orland Firefighter's Pension Board (the Board) terminated the work-related disability pension of plaintiff Eric Hoffman, a decision the circuit court reversed. The plaintiff was awarded a disability pension by the Board in 2002 by a three to two vote, following a 2001 injury he sustained while performing his firefighter duties. In 2010, the Board held a hearing to examine whether the plaintiff should continue to receive his disability pension. The plaintiff's personal physician testified that the plaintiff remained physically incapable of performing the full duties of a firefighter. The Board's doctor, based on his examination of the plaintiff and his review of the available medical records dating back to the plaintiff's original injury in 2001, testified that the plaintiff had no objective manifestations of a physical disability and that his only ailment was a subjective claim of pain. The Board's doctor opined that the plaintiff was never rendered disabled by his 2001 injury. The Board terminated the plaintiff's pension.  The circuit court reversed, ruling that the only evidence supporting the termination was that the plaintiff never sustained a disability, which rendered the Board's decision against the manifest weight of the evidence because no proof was presented that the plaintiff had recovered from his disability. We agree with the circuit court and affirm.

4.   Mortgage Foreclosure: Affirmed: The law of the case doctrine encompasses a court's explicit decisions, as well as those issues decided by necessary implication.  Section 15-704(c) of the Act explicitly conditions a receiver's duties, including the duty to maintain the property. The Act provides that the receiver's duties apply only: “to the extent the receiver receives sufficient receipts from the mortgaged real estate, such other property or other sources.”  An assignment is a contract and is interpreted or construed according to the rules of contract construction.  The cardinal rule of contract interpretation is to discern the parties' intent from the contract language.” Epstein, J.

No. 2012 IL App (1st) 112174  CNA International, Inc. v. Baer  Filed 11-21-12 (LJD)

In this consolidated appeal, plaintiffs, CNA International, Inc. (CNA), and Gold Coast Development, LLC, appeal the trial court's orders: (1) granting the motion of defendants Steven H. Baer and Rally Capital Service, LLC, to dismiss counts I through IV of plaintiffs' second amended complaint; (2) discharging Baer as receiver; (3) granting defendant Cole Taylor Bank's motion to dismiss counts V and VI  of plaintiffs' second amended complaint; and (4) denying plaintiffs' request to file a third amended complaint. For the reasons that follow, we affirm.

5.  Mandatory Arbitration/Discovery Sanctions: Reversed and Remanded: A trial court's decision barring a party from rejecting an arbitration award is subject to an abuse of discretion standard of review.  An abuse of discretion occurs where the trial court's decision is arbitrary or exceeds the bounds of reason.  To warrant such deference, the sanction decision must be factually and legally informed and reasoned.  To the extent that our decision turns on the interpretation of Supreme Court Rule 91(b), we apply a de novo review to the interpretation.   De novo consideration means we perform the same analysis that a trial judge would perform.  The express purpose of Rule 91(b) was to ‘prevent the abuse of the arbitration process and to uphold the integrity of the arbitration process.'   The imposition of sanctions against a party for noncompliance with discovery rules is a matter within the broad discretion of the trial court.  When a trial court determines whether noncompliance with discovery rules was unreasonable, it must consider whether the offending party's conduct is a deliberate and pronounced disregard both for the discovery rules and for the court.  Six factors to determine what sanction is appropriate are listed.  In balancing these factors, the trial judge should weigh "the parties’ rights to maintain a lawsuit against the necessity to accomplish the objectives of discovery and promote the unimpeded flow of litigation."  In light of the six factors which our supreme court requires a trial court to consider, self executing orders should be considered carefully.  Gordon, J. Garcia, J., specially concurring.

No. 2012 IL App (1st) 122555   Reyes v. Menard, Inc.   Filed 11-21-12 (LJD)

Plaintiff Gloria Reyes appeals the trial court’s order granting defendant’s motion to bar plaintiff’s rejection of an arbitration award for defendant and the self-executing order that entered a sanction automatically barring plaintiff from testifying and presenting evidence if the order was not complied with on a date certain.  For the following reasons, we reverse the barring of the arbitration award and grant plaintiff's motion to reject the award.

6.  Workers Compensation: Affirmed: Once an employee has collected compensation on the basis that his or her injuries were compensable under the Act, the employee cannot then allege that those injuries fall outside the Act’s provisions.  Accordingly, we conclude that, once plaintiff applied for and accepted workers’ compensation benefits, she was barred from pursuing an intentional-tort action against defendants. Hutchinson, J.

No. 2012 IL App (2nd) 111303   Glasgow v. Associated Banc-Corp   Filed 11-21-12 (LJD)

Plaintiff, Takeisha Glasgow, appeals the trial court’s dismissal, pursuant to section 2-619.1 of the Code of Civil Procedure (the Code) (735 ILCS 5/2-619.1 (West 2008)), of plaintiff’s amended complaint against defendants, Associated Banc-Corp and Associated Banc-Corp—Lindenhurst Branch.  We affirm.

7.  Traffic Court/Criminal Law: Affirmed:  Permission from prior state's attorney for municipality to prosecute DUI's sufficient.  When faced with a challenge to a circuit court's decision on a motion to quash arrest and suppress evidence, we grant great deference to the court's findings of historical fact and will not disturb those findings unless they are against the manifest weight of the evidence.  Only the facts known to the officer at the time of the stop can be considered in determining whether it was proper–information gained after the stop is made must be disregarded." Carter, J.

No. 2012 IL App (3rd) 110904 City of East Peoria v. Palmer    Filed 11-20-12 (LJD)

The defendant, Bradford Palmer, was charged with driving under the influence (DUI) pursuant to section 11-501(a)(2) of the Illinois Vehicle Code (Code) (625 ILCS 5/11-501(a)(2) (West 2010)). He filed a petition to rescind the statutory summary suspension of his license, which the circuit court granted after finding that the arresting officer lacked a reasonable, articulable suspicion of criminal activity to justify  the traffic stop. Shortly thereafter, the defendant filed a motion to quash his arrest.  After a hearing, the court granted the motion to quash.

6 Appellate Cases Posted 11-20-12

1. Criminal Law/Traffic: Affirmed: Trial court determination that police officer did not testify credibly regarding his observations of defendant's driving supported finding that officer did not have reasonable, articulable suspicion to stop defendant's vehicle, and information from casino transmitted to police did not justify stop of defendant's vehicle, where observations of officer did not coincide with information transmitted to police, and defendant's motion to quash arrest properly granted. Carter, J.

No. 2012 IL App (3d) 110904  City of East Peoria v. Palmer  Filed 11-20-12 (TJJ)


The defendant, Bradford Palmer, was charged with driving under the influence (DUI) pursuant to section 11-501(a)(2) of the Illinois Vehicle Code. He filed a petition to rescind the statutory summary  suspension of his license, which the circuit court granted after finding that the arresting officer lacked a reasonable, articulable suspicion of criminal activity to justify the traffic stop. Shortly thereafter, the defendant filed a motion to quash his arrest. After a  hearing, the court granted the motion to quash. On appeal, the municipality of East Peoria argues that: (1) the court erred when it found that the arresting officer lacked a reasonable, articulable suspicion of criminal activity to stop the defendant's vehicle; (2) the arresting officer had probable cause to    arrest the defendant for DUI; and (3) the court erred when it refused to admit into evidence an audio recording of a call from Par-A-Dice casino security to the East Peoria police. We affirm.

2. Real Estate Law: Affirmed: In real estate contracts where plaintiffs sought to buy units from developer of as-yet developed town home project, defendants' effort to increase price of each unit constituted a breach of contract, but plaintiffs entitled only to nominal damages and return of their earnest money, as damages were speculative in light of the fact that the development had not been built by the time of rial and there was thus no way to establish the value of the particular units, and defendants did not violate Illinois Consumer Fraud and Deceptive Business Practices Act. Quinn, J.

No. 2012 IL App (1st) 111478  Martinez v. River Park Place  Filed 11-20-12 (TJJ)


Plaintiffs, Al A. Martinez and Greg Campos, appeal from an order of the circuit court of Cook County finding that plaintiffs' damages arising from defendant's breach of their contracts to purchase two condominium units in a planned development in Elgin,  Illinois, were limited to a return of plaintiffs' earnest money and nominal damages of $1 each. The order was issued in response to defendant's motion to reconsider the trial court's memorandum opinion, issued after a bench trial, finding that defendant had  breached the contracts by terminating plaintiffs' purchase agreements when they would not agree to an increase in the purchase price and awarding damages to each plaintiff equal to the difference between the increased price and the contract price for their  condominium units. Plaintiffs also appeal from the trial court's finding that defendant did not violate the Illinois Consumer Fraud and Deceptive Business Practices Act, by increasing the  purchase price of the condominium units in order to coerce plaintiffs to either agree to the price increase or terminate their purchase agreements. On appeal, plaintiffs argue that: (1) the trial court erred in finding that they failed to present evidence to  support an award of damages more than the return of their earnest money; and (2) the trial court's finding that defendant did not violate the Consumer Fraud Act was contrary to law and against the manifest weight of the evidence. For the reasons set forth  below, we affirm the trial court.

3. Illinois Consumer Fraud and Deceptive Business Practices Act: Certified Questions Answered: Under the Act, a private individual alleging that any defendant has violated the Act must allege actual damages to have standing to sue under the Act, while the Attorney General need only allege a violation or violations of the Act to have standing to bring an action, and need not allege or prove actual damages. Connors, J. (Quinn, J., sp. concurring).

No. 2012 IL App (1st) 120308  People, ex rel. Madigan v. United Construction of America  Filed 11-20-12 (TJJ)


This appeal presents two certified questions that deal with the pleading requirements for an action by the Attorney General under the Illinois Consumer Fraud and Deceptive Business Practices Act. The first question concerns the pleading requirements for a claim under section 2 of the Act, and the second concerns the pleading requirements for obtaining injunctive and other relief under section 7. We do not need to explain much about the background of this case in order to answer the certified questions.  Defendants are all involved in some fashion with the mortgage and home repair industries in Illinois. The complaint alleges that defendants approach unsophisticated homeowners, usually elderly ones from predominantly African-American communities,  and offer to provide home repair services and financing in order to pay for those services. If the homeowners decline, defendants instead offer to provide mortgage refinancing services. The problem with this business model, the complaint alleges, is that  defendants then push the homeowners into high-risk and unaffordable financing arrangements and steer the resulting home-repair contracts to companies that, among other things, fail to complete the work in a professional manner, if at all. The complaint  alleges that this is all accomplished through a variety of deceptive and unfair business practices.

4. Criminal Law: Affirmed: Error by State in closing argument in defendant's bench trial as to inadmissible prior consistent statement by prosecution witness would not warrant overturning trial court finding of guilty where there was no indication that trial court relied on improper evidence in reaching its finding, and fine order modified to reflect credit for time in custody. Burke, J.

No. 2012 IL App (2d) 110769  People v. Burton  Filed 11-20-12 (TJJ)


Following a bench trial, defendant, Jerry Burton, was convicted of being an armed habitual criminal, unlawful possession of a weapon by a felon, and unlawful use of a weapon. The trial court denied defendant’s posttrial motion for reconsideration of the  finding of guilty and for a new trial. Thereafter, the trial court sentenced defendant to six years in prison followed by a three-year term of mandatory supervised release. Defendant was assessed a $400 fine and $310 in costs. Defendant timely appealed. The  issues are: (1) whether the State’s comment during closing arguments that the testimony of its key witness was credible, because the witness had given a prior consistent statement to the police immediately after the incident, warrants a new trial under the  plain error doctrine; and (2) whether defendant is entitled to monetary credit against his $400 fine, where he spent 86 days in presentencing custody. For the reasons that follow, we affirm the judgment as modified to reflect full credit awarded against  defendant’s fine.

5. Criminal Law: Affirmed: Trial court's erroneous admonition to defendant at sentencing hearing that he was eligible for TASC probation, where defendant was in fact statutorily ineligible, did not invalidate plea of guilty and penitentiary sentence. Schostok, J.

No. 2012 IL App (2d) 110559  People v. Williams  Filed 11-20-12 (TJJ)


Defendant, Anthony Williams, pleaded guilty to retail theft. Following the denial of his motion to withdraw his plea, defendant timely appealed. He argues that he should be allowed to withdraw his plea, because the trial court, when admonishing defendant  concerning the sentencing range, erroneously admonished him that he was eligible to elect treatment under section 40-5 of the Alcoholism and Other Drug Abuse and Dependency Act (the Act) (20 ILCS 301/40-5 (West 2010)), if given probation  (commonly referred to as Treatment Alternatives to Street Crime or “TASC” probation). For the reasons that follow, we affirm.

6. Certified question answered: In civil action by wife against husband and husband's attorney alleging a plot to kill plaintiff Code of Civil Procedure prohibits, with qualification, Illinois Department of Corrections from revealing identity of confidential informant who purportedly told authorities about plot to kill plaintiff while her husband was incarcerated in the Illinois Department of Corrections. Burke, J.

No. 2012 IL App (2d) 120391  Mahoney v. Gummerson  Filed 11-20-12 (TJJ)


This matter comes before the court as a permissive interlocutory appeal brought pursuant to Illinois Supreme Court Rule 308 (eff. Feb. 26, 2010). The questions certified arose from a proceeding in which plaintiff, Carolyn Mahoney, filed a civil action  against defendants, her former husband, Billy J. Cox, and his attorney, R. Marc Gummerson, for allegedly engaging in a plot to kill Mahoney. Mahoney served a subpoena on the Illinois Department of Corrections (Department), seeking the disclosure of the identity and statements of a confidential informant who assisted the Department in its investigation of the alleged murder-for-hire plot. After denying the Department’s motion to quash the subpoena, the trial court certified three questions to this court. We  granted the Department’s application to review two of the three certified questions: “1. Whether 735 ILCS 5/8-802.3 [(West 2010)] precludes disclosure of a CI’s [confidential informant’s] identity in a civil action involving allegations of a murder-for-hire  plot but where no criminal prosecution is being conducted. 2. If not, whether the Department must affirmatively prove that the interest in protecting the CI’s identity outweighs the seeking party’s need for the identity, including that disclosure will impose a  risk to the safety of the CI, and that disclosure will discourage other citizens from providing information to law enforcement.”

 

4 Appellate Cases Posted 11-19-12

1. Sexually Violent Persons Commitment Act: Affirmed and remanded: Prosecutor's argument was not prejudicial; respondent proved to be a sexually violent person beyond a reasonable doubt; cause remanded for trial court error in refusing to give respondent an opportunity to present evidence at dispositional hearing beyond that adduced at trial. Steele, J.

No. 2012 IL App (1st) 112191  In re Commitment of Fields  Filed 11-14-12 (TJJ)


Following a jury trial in the circuit court of Cook County, respondent Justin Fields was found to be a sexually violent person (SVP) under the Sexually Violent Persons Commitment Act. The trial court  subsequently entered an order committing respondent to a secure facility for institutional care and treatment. On appeal, respondent argues that: (1) he was denied a fair trial when the prosecution improperly commented about his custodial status and nonparticipation in treatment, as well as improperly
argued testimony from the State's expert witnesses as substantive evidence, during its closing argument that shifted the burden of proof and violated orders in limine; (2) the trial court erred in denying his motion for mistrial based upon the prosecution's  allegedly improper remarks during closing argument; (3) the State failed to prove beyond a reasonable doubt that he was an SVP under the Act; and (4) he was denied his right to a dispositional hearing under the Act before the commitment order was entered. While we reject respondent's challenges to the prosecutor's remarks during closing argument and the sufficiency of the evidence against him, we remand the cause to the trial court to conduct a dispositional hearing  allowing respondent to present testimony and evidence for its consideration in framing the commitment order.

2. Criminal Law: Appeal dismissed: In case where defendant was found guilty, then found unfit for sentencing, then filed appeal of trial court's decision finding him unfit, despite subsequent restoration to fitness, pendency of appeal regarding fitness prohibited trial court from thereafter resolving defendant's post-trial motions and sentencing defendant, and ruling on post-trial motion and sentence were void. Birkett, J.

No. 2012 IL App (2d) 110059  People v. Mutesha  Filed 11-19-12 (TJJ)


Defendant, Ronex Mutesha, appeals his conviction of aggravated battery to a peace officer. He contends that the trial court erred when it denied his request to discharge his public defender and represent himself for posttrial motions and sentencing. The  State contends that the denial was proper because there was a bona fide doubt as to his fitness. However, although defendant was fit when the court decided the posttrial motions and sentenced him, his appeal of a prior unfitness determination was still  pending. We determine that, under People v. Elsholtz, 136 Ill. App. 3d 209 (1985), because that appeal was still pending, the trial court lacked jurisdiction to rule on the posttrial motions and sentence defendant. Accordingly, its orders on those matters are void, we vacate the denial of defendant’s posttrial motions and his sentence, and we dismiss the appeal.

3. Attorneys' Fees: Affirmed: In dispute between highway road district and commissioners, on the one hand, and township district and its commissioners on the other, Highway Code authorized payment of road district's attorney's fees where a conflict of interest existed between township attorney and road district. McLaren, J.

No. 2012 IL App (2d) 111317  Newport Township Road District v. Pavelich  Filed 11-19-12 (TJJ)


Defendants appeal the trial court’s order that the Newport township board allocate funds from the road district’s budget for payment of plaintiffs’ legal fees. On appeal, defendants argue that: (1) the trial court erred by denying their motion to dismiss; (2)  the Newport Township highway commissioner was not justified in retaining independent counsel; (3) there is no authority for ordering a township board to review a petition for attorney fees and to establish a budget item to pay the fees; (4) plaintiffs were  not entitled to fees springing from a lawsuit filed in 2009; and (5) the township board is vested with exclusive discretion in annual budgetary matters involving the road district. We affirm.

4. Criminal Law: Affirmed: State's argument did not improperly define reasonable doubt; special prosecutor not required in case where county sheriff was brother of president of corporation allegedly victimized in theft case by defendant; defendant proved guilty beyond a reasonable doubt; and trial counsel not ineffective for failing to present expert testimony regarding operation of ATM machine. Carter, J.

No. 2012 IL App (3d) 110385  People v. Max  Filed 11-19-12 (TJJ)


After a jury trial, defendant, Billie S. Max, was convicted of theft in excess of $10,000 and sentenced to a period of probation and county-jail time and ordered to pay restitution. Defendant appeals her conviction, arguing that: (1) the State committed  reversible error by improperly attempting to define reasonable doubt for the jury in rebuttal closing argument; (2) the trial court erred in denying defendant's posttrial motion to appoint a special prosecutor; (3) her trial counsel was ineffective; (4) she was  not proven guilty beyond a reasonable doubt; and (5) she was denied a fair trial because of the cumulative effect of various trial errors. We affirm the trial court's judgment.

2 Appellate Cases Posted 11-16-12

1.  Insurance Law: Affirmed: Appellate procedure  and post trial motion procedure discussed regarding a motion to amend filed within 30 days after judgment.  An occurrence based policy provides an insured with continuing coverage even after the policy period expires.  In a claims made policy, two events must occur to trigger coverage: (1) the claim must arise during the policy period; and (2) the claim must be reported during the policy period.  Retroactive dates frequently are used in insurance contracts in general, when a determination is made that an insured will no longer receive coverage, and the policy is later amended to reflect that fact.   Gordon, J.

No. 2012 IL App (1st) 103834  Geisler v. Everest National Insurance Company  Filed 11-16-12 (LJD)


Plaintiff Fred Geisler, M.D., filed this suit claiming that defendants Everest National Insurance Company (Everest) and Western Litigation, Inc. (Western) breached its duties under the Everest insurance policy (Everest Policy) regarding two medical malpractice lawsuits in which plaintiff was a named defendant (Townsley Lawsuit and Lalicata Lawsuit). Defendants responded claiming that plaintiff failed to state a claim for breach of the Everest Policy regarding its defense of the Townsley Lawsuit, and that the Everest Policy did not provide plaintiff with coverage for the Lalicata  lawsuit.  In this appeal, plaintiff seeks to reverse the circuit court’s orders granting summary judgment in favor of defendants.

2.  Administrative Review/Labor Law: Reversed:  Opinion lists  three standards of review of the Board's decision, depending on the nature of the question being considered.  Section 6 of the Act provides "[e]mployees of the State *** have, and are protected in the exercise of,  the right to self-organization, and may form, join or assist any labor  organization, to bargain collectively through representatives of their own choosing on questions of wages, hours and other conditions of employment." 5 ILCS 315/6(a) (West 2008). The Act defines "employees" as "individual[s] employed by a public employer, *** excluding *** supervisors.  In order to ensure that a pro-union bias will not impair a supervisor's ability to apply the employer's policies to subordinates in accordance with the employer's best interests, the Act provides that a bargaining unit may not contain both supervisors and nonsupervisors.   An individual is a supervisor if all three of the following propositions are true: (1) the individual has principal work substantially different from that of his or her subordinates; (2) the individual has authority on the employer's behalf to perform at least one of the outlined indicia of supervisory authority—namely, the authority to hire, transfer, suspend, lay off, recall, promote, discharge, direct, reward, or discipline employees, to adjust their grievances, or effectively recommend any of those actions—and consistently uses independent judgment in doing so; and (3) the individual spends a preponderance of his time in the job performing supervisory tasks.  Pope, J.

No. 2012 IL App (4th) 110013  The Department of Central Management Services v. The Illinois Labor Relations Board  Filed 11-16-12 (LJD)


Petitioners, the Department of Central Management Services (CMS), the Illinois Departments of Public Health (DPH) and Natural Resources (DNR), and the Illinois Environmental Protection Agency (EPA) bring this action for direct review of a decision by the Illinois Labor Relations Board, State Panel (Board), declaring the American Federation of State, County, and Municipal Employees, Council 31 (Council 31), to be the exclusive bargaining representative of a group of professional engineers with the job title senior public service administrator (option 8E), employed  at DPH, DNR, and EPA.  Petitioners appeal, arguing the option 8Es were supervisory employees within the meaning of section 3(r) of the Act (5 ILCS 315/3(r) (West 2008)). We reverse.

2 Appellate Cases Posted 11-15-12

1. Contract Law/Personal Guaranty: Affirmed: Evidence supported trial court decision that contract language and construction of signature line in contract form supported trial court decision that individual defendant was properly deemed to have obligated himself to guarantee corporate contractual obligation. Fitzgerald Smith, J.

No. 2012 IL App (1st) 120069  Yellow Book Sales and Distribution Company, Inc. v. Feldman  Filed 11-15-12 (TJJ)


This is a collection case, arising from several contracts entered into by the plaintiff, Yellow Book Sales and Distribution Company, Inc. (Yellow Book), and the defendant, David Feldman (Feldman). As president of Glassworks, Inc. (Glassworks), Feldman  negotiated and signed four contacts for advertising services with Yellow Book. On each occasion, Feldman signed the contracts with his name, followed, by "President" or "Pres." When Glassworks went out of business and failed to pay the remaining  balance owed on the four contracts, Yellow Book sued Feldman as the purported guarantor. Following a bench trial, the court found Feldman personally liable under the guarantee. The parties then stipulated to the judgment amount ($13,178.01). Feldman   now appeals, contending that the trial court's finding that he intended to be bound personally under the guarantee was against the manifest weight of the evidence. For the reasons that follow, we affirm.

2. Legal Malpractice: Affirmed: Appeal by plaintiff that trial court improperly dismissed fraud count alternatively pleaded in legal malpractice action deemed waived under application of Foxcroft rule, and dismissal was proper in any event, and jury award of damages was within range supported by the evidence despite plaintiffs' claim that they were entitled to more. Zenoff, J. (McLaren, J., sp. conc.).

No. 2012 IL App (2d) 110718  Gaylor v. Campion, Curran, Rausch, Gummerson and Dunlop, P.C.  Filed 11-15-12 (TJJ)


Plaintiffs, Robert W. Gaylor (Robert), Joann A. Gaylor, Robert E. Gaylor (Bobby), and Morna Gaylor, filed a two-count second amended complaint against defendants, Campion, Curran, Rausch, Gummerson & Dunlop, P.C. (the Campion firm), and Lee C. Lockwood, an associate attorney of the Campion firm, alleging legal malpractice and common-law fraud. The trial court dismissed the fraud count, and the matter proceeded to trial on plaintiffs’ one-count third amended complaint alleging legal malpractice only. The jury returned a verdict in favor of plaintiffs and awarded them damages of $182,625. Plaintiffs appeal, arguing (1) that the trial court erred in dismissing their fraud count and (2) that the jury’s determination of damages was manifestly inadequate  and ignored proven elements of damages. For the following reasons, we affirm.

2 Appellate Cases Posted 11-14-12

1. Criminal Law: Affirmed: In predatory criminal sexual assault case, where defendant had a prior predatory criminal sexual assault conviction which would ordinarily mandate a sentence of natural life for subsequent conviction, where parties did not formally present that fact to the trial court, even though the trial court knew of prior conviction through 402 conference and reference to it at plea hearing, defendant's negotiated sentence of 47.5 years was not void, and defendant's 2-1401 petition was properly denied. Birkett, J.

No. 2012 IL App (2d) 1200060  People v. Hubbard  Filed 10-17-12 (TJJ)


Defendant, Roy E. Hubbard, appeals from the dismissal of two petitions under section 2-1401 of the Code of Civil Procedure in which he sought to vacate his 2006 conviction of aggravated criminal sexual assault (bodily  harm). That conviction was entered under a plea agreement by which defendant received a sentence of 47˝ years’ imprisonment. During a conference pursuant to Illinois Supreme Court Rule 402 before the court’s acceptance of the agreement, the parties advised the court of  defendant’s prior conviction of predatory criminal sexual assault of a child, but the parties did not formally stipulate to the conviction’s existence and the court did not take  judicial notice of it. In his petitions, defendant asserted that, under the recidivist    sentencing provision of section 12-14(d)(2) of the Criminal Code of 1961, the existence of the earlier conviction meant that the only statutorily authorized sentence was a life sentence. He argued that, as a consequence, the sentence, the plea agreement, and the conviction all were void. Affirmed.

2. Domestic Relations Law: Affirmed: Where marital settlement agreement provided that child support provision was "in lieu of" any other provision for children's education support, trial court properly applied Section 505 of Marriage and Dissolution Act rather than Section 513 in granting wife's petition to modify child support based on an increase in husband's income and an increase in education costs. Carter, J. (McDade, J., concurring in part and dissenting in part).

No. 2012 IL App (3d) 110608  In re Marriage of Razzano  Filed 11-14-12 (TJJ)


The petitioner, Brenda Lynn Razzano, now known as Brenda Lynn Gorski, filed a motion to modify child support, alleging changes in circumstances in the income of her ex-husband, Dana Louis Razzano, and in the needs of the parties' two children, Maria  and Joseph. Brenda also filed, in the alternative, a petition for educational support. The circuit court granted Brenda's motion to modify child support, and Dana appealed. On appeal, Dana argues that the court erred when it modified child support pursuant   to section 505(a) of the Illinois Marriage and Dissolution of Marriage Act, rather than under section 513(a)(2) of the Act. We affirm.

4 Appellate Cases Posted 11-13-12

1.  Domestic Relations/Maintenance: Affirmed:  The petition to extend maintenance sought a general review of maintenance, and therefore petitioner was not required to prove a substantial change in circumstances. Considering the statutory factors, the trial court determined "that an award [of] permanent maintenance is appropriate." The trial court did not abuse its discretion. The trial court's decision to impute $37,500 of annual income to Susan was not an abuse of discretion. The trial court did not err in utilizing income averaging to determine Nick's available income for maintenance. Harris, J.

No. 2012 IL App (1st) 101786      In re Marriage of Digiovanni    Filed 11-13-12 (RJC)

Petitioner Susan DiGiovanni appeals the order of the circuit court denying her petition to extend maintenance and granting respondent Nick DiGiovanni's petition to modify maintenance. On appeal, Susan contends the trial court (1) erred in characterizing her petition as a petition to modify support instead of a petition to review support; (2) erroneously applied the substantial change in circumstances standard to her petition; (3) erred in granting Nick's petition to modify maintenance and in determining the amount of maintenance; (4) erred in making the decreased maintenance
retroactive to February 9, 2009; (5) erroneously applied the penalty clause of the parties' marital settlement agreement (MSA), finding Susan and her attorneys liable for respondent's attorney fees; and (6) abused its discretion in awarding Nick $78,500 in attorney fees. Affirmed.

2. Criminal Law/Pleas/Motion to w/draw plea: Vacated and remanded with directions.: It is well established that “[d]efense counsel must strictly comply with Rule 604(d)’s certificate requirement, and, when counsel fails to do so, the case must be remanded to the trial court for proceedings in compliance with the rule.”The certificate here did not explicitly state that counsel ascertained defendant’s contentions of error in the sentence, even though the motion included a request to reconsider the sentence. Thus, counsel did not comply with the rule.  McLaren, J.

No. 2012 IL App (2d) 110646      People v. Dryden     Filed 11-13-12 (RJC)   

Defendant, Stephen H. Dryden, pleaded guilty to aggravated driving under the influence of alcohol (625 ILCS 5/11-501(a)(2), (d) (West 2010)). The trial court sentenced him to 20 years’ imprisonment. Defendant subsequently moved to withdraw the plea and to reconsider the sentence. The trial court denied the motion and defendant appeals. He contends that he is entitled to a new hearing on his motion because his attorney’s certificate did not comply with Illinois Supreme Court Rule 604(d) (eff. July 1, 2006) in that it did not state that the attorney had consulted with defendant to ascertain his contentions of error in the sentence. We vacate and remand.

3. Criminal Law/Speedy Trial: Affirmed: Because defendant did not make a sufficient demand for trial on the record pursuant to section 103-5(a) between August 10, 2010, and February 9, 2011, those delays are considered “agreed to” by defendant.  Accordingly, his claim of ineffective assistance of counsel necessarily fails because a motion by defense counsel for a dismissal on speedy-trial grounds would have been futile.  Hutchinson, J. 

No. 2012 IL App (2d) 110396      People v. Thompson       Filed 11-13-12 (RJC)    
   
In May 2010, the State charged defendant, John M. Thompson, with two counts of domestic battery (720 ILCS 5/12-3.2(a)(1), (a)(2) (West 2010)), one count of battery (720 ILCS 5/12-3(a)(2) (West 2010)), and one count of resisting a peace officer (720 ILCS 5/31-1 (West 2010)), and defendant was released on bond. Thereafter, the State charged defendant with an unrelated felony and defendant was taken back into custody. The State initially opted to try the felony case first for speedy-trial purposes pursuant to section 103-5(a) of the Code of Criminal Procedure of 1963 (the speedy-trial statute) (725 ILCS 5/103-5(a) (West 2010)). Before bringing defendant to trial in either action, however, the State changed its election and brought defendant to trial in the current matter first for the purposes of a speedy trial. A jury found defendant guilty of resisting a peace officer, and the trial court sentenced defendant to time served. Defendant now appeals his conviction, contending that he was denied the effective assistance of counsel because his trial counsel did not file a motion to dismiss the charges on the basis that the State failed to bring him to trial within the speedy-trial term. We affirm.

4. Consumer Fraud Act: Affirmed: All of the requirements for res judicata to apply are present here. There was a final judgment on the merits rendered by a court of competent jurisdiction, there was an identity of causes of action, and there was an identity of parties. Accordingly, the plaintiff's action against American Express is barred by principles of res judicata.  Claims against an attorney for misconduct in representing another client while engaged in the practice of law are not allowed under the Act. Welch, J. 

No. 2012 IL App (5th) 120110        Kosydor v. American Express Centurion Services Corporation        Filed 11-13-12 (RJC)            
   

On November 12, 2010, Ron E. Kosydor filed in the circuit court of Union County a complaint against the defendants, American Express Centurion Services Corporation and American Express Bank, F.S.B. (hereinafter referred to collectively as American Express), and Baker, Miller, Markoff & Krasny, LLC (hereinafter referred to as the law firm). The complaint alleged that American Express and its law firm had violated the Illinois Consumer Fraud and Deceptive Business Practices Act (the Act) (815 ILCS 505/1 to 12 (West 2008)) by engaging in debt collection activities against the plaintiff which were malicious and fraudulent because the defendants knew that the plaintiff did not owe them any money.  The defendants filed a motion to dismiss the plaintiff's complaint pursuant to sections 2-619(a)(4) and (a)(9) of the Illinois Code of Civil Procedure (the Code) (735 ILCS 5/2-619(a)(4), (a)(9) (West 2010)). On December 19, 2011, the circuit court of Union County entered an order dismissing with prejudice the plaintiff's complaint. The court ruled that the Act does not apply to attorneys. The court further ruled that res judicata did apply to bar the action against American Express.

3 Appellate Cases Posted 11-9-12

 

1.  Insurance Law: Affirmed:  The construction of an insurance policy and a determination of the rights and obligations thereunder are questions of law for the court which are appropriate subjects for disposition by way of summary judgment.  Initially, we note that in Illinois, the duties to defend and to indemnify are not coextensive, with the obligation to defend being broader than the obligation to pay.   In determining whether an insurer has a duty to defend its insured, a court looks to the allegations in the underlying complaint and compares them to the relevant provisions of the insurance policy.  Where an exclusionary clause is relied upon to deny coverage, its applicability must be clear and free from doubt because any doubts as to coverage will be resolved in favor of the insured.  Both parties acknowledge that, as an attorney, Greenfield had a duty to disclose his mistake to the beneficiaries.  The case at bar is essentially a case of first impression, as there is only one Illinois case that concerns the question of whether an insured admitted liability in violation of a provision of his insurance policy.  An admission of fault did not amount to an assumption of liability, since it amounted only to an admission of the truth of the fact from which liability might flow, while an assumption of liability brought into existence a contractual obligation.  We find that a provision such as the one at issue here is against public policy, since it may operate to limit an attorney’s disclosure to his clients.  Gordon, J., special concurrence by Garcia, J.

No. 2012 IL App (1st) 110337   Illinois State Bar Association Mutual Insurance Company v. Frank M. Greenfield and Associates, P.C.  Filed 11-09-12 (LJD)

This appeal is essentially a case of first impression and concerns whether an admission of error in a legal malpractice claim by a policyholder without his insurance company’s approval gave the company the right to deny coverage and not defend the attorney and his law firm.  Attorney Frank M. Greenfield admitted to making a mistake in drafting a client’s will that affected the distribution of funds from a trust established by his client.  Greenfield had a professional liability insurance policy through Illinois State Bar Association Mutual Insurance Company (ISBA Mutual), but did not inform ISBA Mutual prior to  sending the letter to the beneficiaries. ISBA Mutual claims that, by failing to inform it of the letter prior to sending it, Greenfield violated a provision of his insurance policy and, consequently, ISBA Mutual had no duty to defend Greenfield in the subsequent legal malpractice action.The trial court also found that even if he had violated the policy, ISBA Mutual was not prejudiced by the breach. ISBA Mutual appeals, and we affirm.

2.  Civil Procedure: Affirmed: The Act "does not 'protect against disclosure of information generated before a peer review process begins or after it ends,' [citation]," and, therefore, "the hospital committee 'must be engaged in the peer review process before the statutory privilege is applicable.'  Our supreme court held that the information that an anesthesiologist obtained from nurses after the incident but before the hospital's peer review meeting: (1) was not privileged because it was not " 'information of' any committee, peer-review or otherwise;" (emphasis omitted); and (2) "was not transformed into information of" a committee simply because the doctor subsequently reported the incident to that committee.   Even when statements are made in anticipation of peer review, the confidentiality provisions of the Act are not invoked until there is a committee meeting on that incident.  Taylor, J.

No. 2012 IL App (1st) 110930   Tunca v. Painter   Filed 11-09-12 (LJD)

Plaintiff, Dr. Josh Tunca, appeals from an order of the circuit court of Cook County granting summary judgment in favor of defendant, Dr. Thomas Painter, on count II of his third amended complaint, which alleged that plaintiff's statements to other doctors about plaintiff's performance violated the confidentiality provisions of section 8-2101 of the Code of Civil Procedure, commonly referred to as the Medical Studies Act.  Plaintiff contends that he has a private right of action for defendant's violation of the Act and that, contrary to the trial court's findings, defendant's statements to other doctors about plaintiff's performance were privileged under the Act.

3.  Insurance Law: Affirmed: To determine whether an insurer has a duty to defend an action against an insured, generally, we compare the allegations of the underlying complaint to the relevant portions of the insurance policy.  "If the complaint alleges facts that fall within or potentially within the coverage of the policy, 'the insurer is obligated to defend its insured even if the allegations are groundless, false, or fraudulent.' "   "If the words in the policy are unambiguous, a court must afford them their plain, ordinary, and popular meaning.  However, if the words in the policy are susceptible to more than one reasonable interpretation, they are ambiguous and will be construed in favor of the insured and against the insurer who drafted the policy."    Garcia, J., special concurrence by Gordon, J.

No. 2012 IL App (1st) 111529   Pekin Insurance Company v. Equilon Enterprises LLC Filed 11-09-12 (LJD)

In this declaratory action arising out of a personal injury suit, the circuit court denied plaintiff Pekin Insurance Co.'s motion for summary judgment on the question of duty to defend and, instead, granted judgment as a matter of law to defendants Equilon Enterprises, d/b/a Shell Oil Products US, and Shell Oil Company (collectively Shell), as additional insureds under the policy. Waldemar Zablocki filed suit for injuries he sustained while lighting a cigarette behind a gas station operated by Summit Shell (Summit), d/b/a Mary's Station II, Inc.  Based on the unclear endorsements, in particular the endorsement that purported to limit coverage to vicarious liability, Pekin has not demonstrated that the allegations of the underlying complaint do not bring the case potentially within the policy's coverage. We affirm the circuit court's judgment that Pekin has a duty to defend Shell.

5 Appellate Cases Posted 11-8-12

1.  Traffic Court/speedy Trial Act: Affirmed:  To establish such a speedy trial violation, a defendant need establish only that he was “not *** tried within the period set by statute and that defendant has not caused or contributed to the delays.  The defendant bears the burden of persuasion under both prongs of the plain-error analysis.  The first step in the plain-error analysis is to determine whether error occurred at all.  The failure of counsel to move for discharge on the basis of a speedy trial violation will constitute ineffective assistance of counsel “when there is at least a reasonable probability that the client would have been discharged had a timely motion been filed and there was no justification for the attorney’s decision not to file a motion.”  The purpose of the statutory right to a speedy trial is to “guarantee a speedy trial and not ‘to open a new procedural loophole which defense counsel could unconsciously use to obstruct the ends of justice.  Birkett, J., dissent by Hutchinson, J.

No. 2012 IL App (2nd) 100736   People v. Wigman   Filed 11-08-12 (LJD)

Following a bench trial, defendant, James J. Wigman, was convicted of driving under the influence of alcohol (DUI) and improper lane usage. 625 ILCS 5/11-501(a)(2), 709(a) (West 2006). Defendant appeals, alleging that his statutory right to a speedy trial was violated. Defendant acknowledges that he failed to preserve the issue but asks us to consider the issue under the plain error doctrine or, alternatively, to find that trial counsel provided ineffective assistance of counsel by failing to move for discharge. We find that there was no error, because there was no lawful basis for raising a speedy-trial objection.

2.  Sovereign Immunity: Affirmed: The purpose of sovereign immunity is to protect the state from interference with the performance of governmental functions and to preserve and protect state funds.  Even though sovereign immunity is barred by the Illinois Consitution, the legislature reinstated the State's sovereign immunity when it passed the State Lawsuit Immunity Act (Immunity Act) (745 ILCS 5/0.01 to 1.5 (West 2010)).   The legislature may, by statute, consent to suit and waive sovereign immunity.  However, the State's consent to be sued must be clear and unequivocal.  Only the legislature has the power to waive sovereign immunity—an officer or agency of the State, such as the Department, lacks the authority to do so.  While suits brought under the [Rights Act] may now proceed in circuit court, there is no clear, affirmative declaration in the [Rights Act] or the Immunity Act that the State has waived its sovereign immunity for [Rights Act] claims.   Knecht, J.

No. 2012 IL App (4th) 111040   Lynch v. The Department of Transportation    Filed 11-08-12 (LJD)

In this consolidated appeal, plaintiffs, Robert D. Lynch and Timothy L. Storm, seek review of the Sangamon County circuit court's orders dismissing their claims under the Illinois Human Rights Act (Rights Act) (775 ILCS 5/art. I (West 2010)) pursuant to the doctrine of sovereign immunity. Both Lynch and Storm sued the State of Illinois, in its capacity as their respective employers, for violations of the Rights Act. Lynch sued the Illinois Department of Transportation (IDOT) for unlawful retaliatory conduct. Storm sued the Illinois State Police (State Police) for unlawful employment discrimination on the basis of age, sex, and sexual orientation. In both cases, the court concluded (1) the Rights Act does not contain clear and unequivocal  language waiving the State's sovereign immunity; (2) the State's sovereign immunity is not waived simply because the Rights Act includes the State in its definition of "employer"; and (3) the State was not estopped from asserting its sovereign immunity despite the letters it sent informing plaintiffs they could "commence a civil action in the appropriate state circuit court."

3.  Workers Compensation: Affirmed: The determination of whether a claimant is entitled to an award of vocational-rehabilitation benefits is a question to be decided by the Commission, and its finding will not be reversed unless it is against the manifest weight of the evidence.  In resolving such a question, it is the function of the Commission to judge the credibility of the witnesses, resolve any conflicts in the testimony, and draw reasonable inferences from the evidence presented.  Vocational rehabilitation may include, but is not limited to, counseling for job searches, supervising a job search program, and vocational retraining including education. 820 ILCS 305/8(a) (West 2010). Yet, section 8(a) is flexible and does not limit rehabilitation to formal training.  Hoffman, J.

No. 2012 IL App (1st) 113129WC  W.B. Olson, Inc. v. Illinois Workers' Compensation Commission Filed 11-08-12 (LJD)

W. B. Olson, Inc. (Olson) appeals from an order of the Circuit Court of Cook County which confirmed a decision of the Illinois Workers' Compensation Commission (Commission), awarding the claimant, Craig Kolin, benefits pursuant to the Workers' Compensation Act (Act) (820 ILCS 305/1 et seq. (West 2008)) for injuries to his right knee that he received while in Olson's employ. For the reasons which follow, we affirm the judgment of the circuit court.

4.  Criminal/Juvenile Justice Procedure: Affirmed:  Whether the criminal charges against defendant were properly filed in the form of an information in the trial court is a legal question involving statutory interpretation. Accordingly, de novo review is appropriate.  Section 5-120 of the Juvenile Court Act of 1987, entitled "Exclusive jurisdiction," defines the persons and crimes covered by delinquency proceedings, as opposed to criminal prosecutions. It provides that the State may institute juvenile delinquency proceedings "concerning any minor who prior to the minor's 17th birthday has violated or attempted to violate, regardless of where the act occurred, any federal or State law or municipal or county ordinance."  Subject to enumerated exceptions, "no minor who was under 17 years of age at the time of the alleged offense may be prosecuted under the criminal laws of this State."  Cook, J.

No. 2012 IL App (4th) 120285  People v. Baum  Filed 11-08-12 (LJD) 

In February 2012, the trial court granted defendant Mason S. Baum's motion to dismiss the State's criminal charges against him, finding that, because defendant was younger than 17 years old when the alleged crimes occurred, the State was required to initiate charges against him in a juvenile delinquency petition. The State appeals, arguing it should not have been precluded from charging defendant in criminal, as opposed to delinquency, proceedings. We disagree and affirm.

5.  Post Conviction Petition: Affirmed: The "law of the case" doctrine bars relitigation of an issue already decided in the same case.  "Rulings on points of law made by a court of review are binding in that case upon remand to the trial court and on subsequent appeals to that same reviewing court unless a higher court has changed the law." Discussion of whether commutation of death penalty moots the post conviction petition and the law in that area.  A trial court's decision on whether or not to grant leave to counsel to file an addendum to an amended postconviction petition is reviewed for an abuse of discretion.  A trial court's decision on whether or not to grant leave to counsel to file an addendum to an amended postconviction petition is reviewed for an abuse of discretion.   McDade, J.

No. 2012 IL App (3rd) 110381   People v. Oaks Filed 11-07-12 (LJD)   

In this appeal, defendant, Douglas E. Oaks, contests the dismissal of his postconviction petition after a third-stage evidentiary hearing. Defendant also challenges the trial court's denial of his request for leave to file supplemental postconviction claims during the third-stage evidentiary hearing. For the reasons stated below, we affirm.

5 Appellate Cases Posted 11-6-12

1. Criminal Law: Affirmed: It is well established that “[d]efense counsel must strictly comply with Rule 604(d)’s certificate requirement, and, when counsel fails to do so, the case must be remanded to the trial court for proceedings in compliance with the rule.”  Nothing in the rule’s plain language requires that, when a defendant is simultaneously represented by multiple attorneys from the same office, each attorney must file a certificate.  Where one attorney prepared and filed the motion and continued to represent defendant throughout the proceedings, a new certificate by other attorney was not required.  Hudson, J. with Jorgensen, J. specially concurring.

No. 2012 IL App (2d) 110666      People v. Mineau    Filed 11-06-12 (RJC)               

  

Defendant, Martinez L. Mineau, was charged with burglary (720 ILCS 5/19-1(a) (West 2008)) and unlawful possession of a stolen motor vehicle (625 ILCS 5/4-103(a) (West 2008)). Pursuant to an agreement with the State, he pleaded guilty to the unlawful-possession charge and the State dismissed the burglary charge. Defendant later moved to withdraw the plea. Following a hearing, the trial court denied the motion. Defendant appeals, contending that the cause should be remanded for a new hearing where the attorney who represented him at the hearing did not file a certificate pursuant to Illinois Supreme Court Rule 604(d) (eff. July 1, 2006) and the certificate that co-counsel filed was insufficient. We affirm.

2. Subject-Matter Jurisdiction: Affirmed: Applying the three-factor analysis,  plaintiff's tort claims are in reality claims against the State. As a result, those claims are barred from consideration by the trial court and should instead be heard in the Court of Claims. Thus, the trial court did not err in granting defendant's motion to dismiss for lack of jurisdiction. Pope, J. 

No. 2012 IL App (4th) 120202    Carmody v. Thompson    Filed 10-03-12 (RJC)
            

In September 2011, plaintiff, Kevin Carmody, filed a complaint against defendant, Charles Thompson, for defamation per se, false light, and tortious interference with contractual relations following plaintiff's termination from the University of Illinois (University). In November 2011, defendant filed a motion to dismiss pursuant to section 2-619(a)(1) of the of the Code of Civil Procedure (Procedure Code) (735 ILCS 5/2-619(a)(1) (West 2010)), arguing the cause should instead be heard in the Court of Claims because defendant's actions were taken pursuant to his University employment. In February 2012, the trial court granted defendant's motion to dismiss. Plaintiff appeals, arguing the trial court erred (1) in granting defendant's motion to dismiss and, in the alternative, (2) denying his request for leave to amend his complaint.

3. Criminal Law/Mental Health/Fitness: Vacated and remanded with directions: Every 90 days after the initial admission under this subdivision (g)(2), the facility director shall file a typed treatment plan report with the original court having jurisdiction over the defendant.  The subject matter of those reports is germane to the issue of whether a defendant is in need of inpatient treatment or can be treated on an outpatient basis. Absent reports that comply with the statute, the trial court will lack the information necessary to make a knowledgeable and, therefore, reliable decision about the appropriate setting in which mental health services should be administered.The trial court erred in proceeding without the required treatment plan reports.  No error as to the issue of defendant's fitness. Zenoff, J. 

No. 2012 IL App (2d) 110856       People v. Olsson    Filed 11-06-12 (RJC)

   
These consolidated appeals arise from orders entered during the period when defendant, Paul Olsson, was in the custody of the Department of Human Services (Department) pursuant to section 104-25(g)(2) of the Code of Criminal Procedure of 1963 (Code) (725 ILCS 5/104-25(g)(2) (West
2010)), which provides for the potentially long-term commitment of a criminal defendant who has been found unfit to stand trial and for whom treatment to attain fitness has been unsuccessful. The period of commitment under this provision may be as long as the maximum sentence for the charged offense. Id. While the defendant is committed under section 104-25(g)(2), the trial court must periodically review his or her condition and treatment needs. Defendant argues that the trial court’s review proceedings were deficient because (1) the facility to which he is committed failed to comply with its statutory duty to report on his treatment and his condition, and (2) the trial court failed to conduct a meaningful hearing to determine whether he had been restored to fitness. We agree with the first argument and therefore vacate the orders and remand for further proceedings. We find no error, however, relative to the question of defendant’s fitness.

4. Gov't. Immunity: Affirmed: Defendant is a local public entity immune from liability for negligence under section 3-106 of the Act. Under section 3-106, defendant is liable to plaintiff only if it proximately caused plaintiff’s injuries by willful and wanton conduct. A plaintiff pleading willful and wanton conduct is required to allege some facts showing that the defendant was aware of circumstances that posed a serious danger.  Plaintiff’s second amended complaint did not contain minimally sufficient allegations of fact from which it could be inferred that defendant, at the time it instructed plaintiff to operate the crank, was conscious of any danger that would “naturally and probably result in injury” or that “posed a high probability of serious physical harm.”  Zenoff, J. 

No. 2012 IL App (2d) 120156      Leja v. Community Unit School District 300    Filed 11-06-12 (RJC)

   
Plaintiff, Allison Leja, appeals from the dismissal of her second amended complaint against defendant, Community Unit School District 300. Plaintiff, a student at a high school owned and operated by defendant, allegedly was injured in her school’s gymnasium when a volleyball net crank she was turning either “broke loose” or “snapped back” and struck her in the face. Plaintiff alleged in her two-count second amended complaint that defendant was negligent (count I) or engaged in willful and wanton conduct (count II). The trial court dismissed count I pursuant to section 2-619(a)(9) of the Code of Civil Procedure (Code) (735 ILCS 5/2-619(a)(9) (West 2008)) after determining that defendant was immune from liability for negligence under section 3-106 of the Local Governmental and Governmental Employees Tort Immunity Act (Act) (745 ILCS 10/3-106 (West 2008)). The court then dismissed count II pursuant to section 2-615 of the Code (735 ILCS 5/2-615 (West 2008)) after determining that plaintiff did not allege sufficient facts to plead willful and wanton conduct under the Act. Both dismissals were with prejudice. On appeal, plaintiff challenges the dismissal of count II only. Plaintiff argues that the warning label on the volleyball net crank was sufficient to put defendant on notice that the crank posed a risk of injury, and that instructing plaintiff to operate the crank bearing the warning label evinced an utter indifference to or conscious disregard for plaintiff’s safety. For the following reasons, we affirm.

5. Gov't. Immunity: Affirmed: The circuit court found plaintiff's calculations as to damages more credible than Orlich's. The circuit court's findings as to damages was  not "arbitrary, unreasonable, or not based in evidence." Harris, J.  

No. 2012 IL App (1st) 112974    Staes and Scallan, P.C. v. Orlich     Filed 11-06-12 (RJC) 

  
Staes & Scallan, P.C., a law firm (plaintiff), filed a verified complaint for breach of contract against defendants, and former clients, P. Daniel Orlich and Jeffrey Gidney.  Defendants each owned a baseball team in the independent Northern League, a professional baseball league (League). Plaintiff sought payment of approximately $56,000 in fees and costs associated with its defense of defendants in a lawsuit brought by the League. Prior to trial, and after having a default judgment and subsequent judgment order entered against him, Gidney settled with plaintiff for $28,000. This amount represented approximately half of the amount plaintiff claimed it was owed from defendants. Following the bench trial against Orlich, the circuit court found in plaintiff's favor on the issue of liability only, taking the issue of damages under advisement. After allowing Orlich and plaintiff to file written submissions outlining their respective positions to charges contained in plaintiff's outstanding invoices, the circuit court entered judgment against Orlich in the amount of $23,397.35, plus prejudgment interest. At issue here is whether the circuit court's judgment order in the amount of $23,392.35, plus prejudgment interest, is against the manifest weight of the evidence. We hold that the circuit court's judgment order is not against the manifest weight of the evidence.

 

3 Appellate Cases Posted 11-6-12

1. Criminal Law: Vacated and remanded: Failure of trial court to require that Department of Human Services provide a 90-day treatment plan for unfit defendant previously involuntarily admitted to Department after a finding of unfitness, where such plan is required by Section 104-25 of Code of Criminal Procedure, rendered 104-25 hearing improper, and cause remanded for proper hearing after submission of proper treatment plan. Zenoff, J.

No. 2012 IL App (2d) 110856  People v. Olsson Filed 11-6-12 (TJJ)


These consolidated appeals arise from orders entered during the period when defendant, Paul Olsson, was in the custody of the Department of Human Services (Department) pursuant to section 104-25(g)(2) of the Code of Criminal Procedure of 1963  (Code) (725 ILCS 5/104-25(g)(2) (West 2010)), which provides for the potentially long-term commitment of a criminal defendant who has been found unfit to stand trial and for whom treatment to attain fitness has been unsuccessful. The period of  commitment under this provision may be as long as the maximum sentence for the charged offense. Id. While the defendant is committed under section 104-25(g)(2), the trial court must periodically review his or her condition and treatment needs.  Defendant argues that the trial court’s review proceedings were deficient because (1) the facility to which he is committed failed to comply with its statutory duty to report on his treatment and his condition, and (2) the trial court failed to conduct a  meaningful hearing to determine whether he had been restored to fitness. We agree with the first argument and therefore vacate the orders and remand for further proceedings. We find no error, however, relative to the question of defendant’s fitness.

2. Tort Law/Governmental Immunity: Affirmed: Trial court order dismissing claim brought on behalf of public high school student for injuries sustained when turning a crank on a volleyball net affirmed, where complaint did not state sufficient facts to show that high school's conduct in using volleyball net was "willful and wanton," where claim by plaintiff only involved a claim that high school was on notice as to danger of the net by virtue of warning label affixed to net. Zenoff, J.

No. 2012 IL App (2d) 120156  Leja v. Community Unit School District 300  Filed 11-6-12 (TJJ)


Plaintiff, Allison Leja, appeals from the dismissal of her second amended complaint against defendant, Community Unit School District 300. Plaintiff, a student at a high school owned and operated by defendant, allegedly was injured in her school’s  gymnasium when a volleyball net crank she was turning either “broke loose” or “snapped back” and struck her in the face. Plaintiff alleged in her two-count second amended complaint that defendant was negligent (count I) or engaged in willful and wanton conduct (count II). The trial court dismissed count I pursuant to section 2-619(a)(9) of the Code of Civil Procedure (Code) (735 ILCS 5/2-619(a)(9) (West 2008)) after determining that defendant was immune from liability for negligence under section   3-106 of the Local Governmental and Governmental Employees Tort Immunity Act (Act) (745 ILCS 10/3-106 (West 2008)). The court then dismissed count II pursuant to section 2-615 of the Code (735 ILCS 5/2-615 (West 2008)) after determining that  plaintiff did not allege sufficient facts to plead willful and wanton conduct under the Act. Both dismissals were with prejudice. On appeal, plaintiff challenges the dismissal of count II only. Plaintiff argues that the warning label on the volleyball net crank  was sufficient to put defendant on notice that the crank posed a risk of injury, and that instructing plaintiff to operate the crank bearing the warning label evinced an utter indifference to or conscious disregard for plaintiff’s safety. For the following reasons,  we affirm.

3. Contract Law/Attorneys' Fees: Affirmed: Defendant's argument that trial court did not rule that the liability owed to plaintiffs was joint and several deemed waived on appeal, and trial court conclusion that defendant owed plaintiffs fees for legal services was not against the manifest weight of the evidence. Harris, J.

No. 2012 IL App (1st) 112974  Staes and Scallan, P.C. v. Orlich  Filed 11-6-12 (TJJ)


Staes & Scallan, P.C., a law firm (plaintiff), filed a verified complaint for breach of contract against defendants, and former clients, P. Daniel Orlich and Jeffrey Gidney. Defendants each owned a baseball team in the independent Northern League, a  professional baseball league (League). Plaintiff sought payment of approximately $56,000 in fees and costs associated with its defense of defendants in a lawsuit brought by the League. Prior to trial, and after having a default judgment and subsequent  judgment order entered against him, Gidney settled with plaintiff for $28,000. This amount represented approximately half of the amount plaintiff claimed it was owed from defendants. Following the bench trial against Orlich, the circuit court found in  plaintiff's favor on the issue of liability only, taking the issue of damages under advisement. After allowing Orlich and plaintiff to file written submissions outlining their respective positions to charges contained in plaintiff's outstanding invoices, the circuit  court entered judgment against Orlich in the amount of $23,397.35, plus prejudgment interest. At issue here is whether the circuit court's judgment order in the amount of $23,392.35, plus prejudgment interest, is against the manifest weight of the evidence.  We hold that the circuit court's judgment order is not against the manifest weight of the evidence.

 

5 Appellate Cases Posted 11-5-12

1. Mortgage Foreclosure: Affirmed: Trial court properly denied motions of defendants (husband and wife) in residential mortgage foreclosure case to quash service of summons, as service upon mother of one defendant (and mother-in-law of other defendant) at household was proper, as mother was a "family member" notwithstanding that she may not have resided at defendants' address. Karnezis, J.

No. 2012 IL App (1st) 112353  Central Mortgage Company v. Kamarauli  Filed 11-5-12 (TJJ)


In this mortgage foreclosure action, defendants Levan Kamarauli and Valeria Mourzaeva appeal from orders of the circuit court denying their motion to quash service of process and their motion to reconsider that ruling, and from the order approving the  sale and granting possession of their residential property to plaintiff, Central Mortgage Company. On appeal, defendants contend that the court erred when it denied their motion to quash service because abode service was not properly attained where the  family member who accepted service at their home did not live in their household. Defendants further argue that service was not proper because the process server mailed only one copy of the summons and complaint in an envelope addressed to both defendants, rather than separately mailing each defendant individual copies of the summons. Defendants claim that due to the improper service, the circuit court lacked personal jurisdiction over them. We affirm.

2. Freedom of Information Act/Police "CR" Files: Reversed and remanded: "CR" files relating to particular police officers, including complaints deemed to be without merit, should have been reviewed in camera by trial court before denying plaintiff's complaint for administrative review of police department's denial of his FOIA request for same. Rochford, J.

No. 2012 IL App (1st) 100632  Watkins v. McCarthy  Filed 11-5-12 (TJJ)


Plaintiff, Kilroy Watkins, an inmate at Lawrence Correctional Center, appeals the dismissal of his complaint against defendant, Garry McCarthy, superintendent of the Chicago Police Department (Department), seeking to compel disclosure, under the state  Freedom of Information Act (FOIA) (5 ILCS 140/1 et seq. (West 2008)), of documents relating to complaints of misconduct made against two police officers. Plaintiff alleged that these officers coerced him into making a confession that led to his first- degree murder and armed robbery convictions. In an order entered January 5, 2012, we initially dismissed this appeal for lack of jurisdiction (Watkins v. McCarthy, 2012 IL App (1st) 100632-U). Pursuant to a supervisory order (Watkins v. McCarthy, No.  114063 (Ill. May 30, 2012) (supervisory order)), our supreme court on, May 30, 2012, directed that we vacate our order and consider the matter on its merits. Having vacated our prior order, and upon consideration of the merits of this appeal, we reverse the  order granting defendant's motion to dismiss and remand this cause to the circuit court for an in camera inspection of the documents requested by plaintiff pursuant to section 11(f) of the FOIA. 5 ILCS 140/11(f) (West 2008).

3. Workers' Compensation: Affirmed in part, reversed in part, and remanded: Commission decision that claimant was an employee of company, and not an independent contractor, not against manifest weight of the evidence, but Commission computation of weekly wage was error, as it should have been based upon average weekly wage of 12-month period preceding injury, notwithstanding company claim that claimant did not work full-time all year. Hoffman, J.

No. 2012 IL App (1st) 113007WC  Labuz v. Illinois Workers' Compensation Commission  Filed 11-5-12 (TJJ)


Both the claimant, Antoni Labuz, and JKC Trucking Co., Inc. (JKC) have appealed from an order of the Circuit Court of Cook County which confirmed a decision of Illinois Workers' Compensation Commission (Commission), awarding the claimant  certain benefits pursuant to the Workers' Compensation Act (Act) (820 ILCS 305/1 et seq. (West 2008)), for neck, back, and left shoulder injuries sustained while in the employ of JKC . We consolidated the two appeals for review.

4. Trusts and Estates: Affirmed: Trial court properly deemed that terms of trust which benefited decedent before his death would operate by its terms as if he had died without children, and adult "children" (one of whom was actually herself a grandmother) "adopted" by him shortly before his death at age 94 were properly not considered as such under the terms of the Probate Act. Steigmann, J.

No. 2012 IL App (4th) 120209  Dixon v. Weitekamp-Diller  Filed 11-5-12 (TJJ)


This case involves three trusts, each of which includes a life estate in the proceeds from farmland for William Hughes Diller, Jr. (Hughes), with the res of each trust to be distributed, at least in part, to Hughes' children at his death. The trusts further provide,  however, that if Hughes were to die without any children, the res of each trust would be distributed to his sisters' children per stirpes. After having spent the first 87 years of his life unmarried, Hughes married his former assistant, Barbara Weitekamp, and  moved with her to Florida. In August 2010, concerned about Barbara's role in Hughes' financial affairs and that she was keeping Hughes away from them, members of Hughes' family filed a complaint to appoint a successor trustee and for declaratory relief. Shortly thereafter, Barbara arranged for then 94-year-old Hughes to adopt three of her adult daughters from a previous marriage. Hughes did so and died several months later. Following an exchange of motions, the trial court ordered the trustees to administer and distribute the trusts as if Hughes did not have any children, finding, in pertinent part, that the adoptions of Barbara's daughters were subterfuge and done "solely to make Barbara's daughters heirs *** under the three trusts." Barbara and her  daughters appeal, arguing that the trial court erred by granting plaintiffs' motion for summary judgment because (1) Illinois law presumes that an adopted child is the descendant of the adoptive parent and (2) the court improperly determined that 63 acres Hughes purchased as trustee of one of the family trusts—which he later transferred to Barbara—should remain part of the trust. We disagree and affirm.

5. Trusts and Estates: Reversed and remanded: Trial court erroneously granted plaintiff trust beneficiary's complaint for termination of trust and distribution to named beneficiaries under doctrine of equitable deviation, based upon claim that fees of bank manager "interfered" with purpose of the charitable trust, where trust grew in manner anticipated by settlor, and fees were generated properly in connection with bank's efforts to comply with I.R.S. private foundation rules. Cook, J.

No. 2012 IL App (4th) 120266  Church of the Little Flower v. US Bank  Filed 11-5-12 (TJJ)


In June 2010, plaintiff, Church of the Little Flower, petitioned the trial court for reformation of a trust of which plaintiff is one of three remaining beneficiaries. Plaintiff asked the court to apply the doctrine of equitable deviation to terminate the trust and  distribute its assets to the beneficiaries. One of the named defendants, US Bank, is currently the trustee of that trust. In December 2011, the court granted summary judgment in favor of plaintiff. The court's judgment required US Bank to dissolve the trust  and distribute its assets to plaintiff and the other two remaining beneficiaries. US Bank appeals, arguing equitable deviation did not apply and reformation of the trust was thus improper. We agree. Accordingly, we reverse and remand with directions to  enter summary judgment for US Bank.

 

3 Appellate Cases Posted 11-2-12

1. Traffic Law: Affirmed: In prosecution for driving while her license was suspended in connection with a statutory summary suspension stemming from a prior arrest for DUI, prosecution was not obligated to prove that defendant was not driving her vehicle as allowed by a monitoring device driving permit. Schostok, J.

No. 2012 IL App (2d) 110557  People v. McPeak  Filed 11-2-12 (TJJ)


Following a stipulated bench trial in the circuit court of Boone County, defendant, Lynette D. McPeak, was found guilty of driving while her license was suspended and was sentenced to a 1-year term of probation and 30 days in the Boone County jail. It  was stipulated that on May 10, 2010, a law enforcement officer conducted a traffic stop of a vehicle driven by defendant. The abstract of defendant’s driving record, which was admitted into evidence by stipulation, showed that a December 6, 2009, arrest in Winnebago County for driving under the influence of alcohol (DUI) resulted in the statutory summary suspension of her driver’s license pursuant to section 11-501.1 of the Illinois Vehicle Code. The abstract indicated that the statutory summary suspension  was in effect when defendant was stopped on May 10, 2010. Defendant argues on appeal that, in order to secure a conviction of DWLS, the State was obligated to prove that she was not operating the vehicle as allowed by a monitoring device driving  permit. According to defendant, because no evidence was presented on this point, her conviction must be reversed. We conclude that the State was under no obligation to present such evidence and we therefore affirm defendant’s conviction.

2. Criminal Law: Vacated and remanded: In light of fact that State had not been served with criminal defendant's Section 2-1401 petition, sua sponte dismissal of petition on merits was premature, and dismissal should have been without prejudice for failure to comply with service requirements of Section 2-1401. McLaren, J.

No. 2012 IL App (2d) 110767  People v. Prado  Filed 11-2-12 (TJJ)


Defendant, Martin Prado, appeals the trial court’s sua sponte dismissal on the merits of his petition for relief from judgment, filed under section 2-1401 of the Code of Civil Procedure (735 ILCS 5/2-1401 (West 2010)). Defendant’s petition was not properly  served on the State. He contends that, under People v. Nitz, 2012 IL App (2d) 091165, ¶¶ 5-6, the trial court acted prematurely and the dismissal should have been without prejudice. We agree that the dismissal was premature. However, we decline to follow Nitz, which resulted in a dismissal without prejudice. Instead, we vacate the dismissal and remand for further proceedings.

3. Mortgage Foreclosure: Reversed and remanded: In mortgage foreclosure action, trial court erred in believing it had no discretion to consider defendant's Section 2-1301(e) motion to vacate default judgment in case where defendant had previously appeared and secured plaintiff's agreement to forestall judicial sale for 75 days; defendant had right to have court consider her motion and exercise its discretion in granting or denying it. NOTE: Case is in acknowledged contradistinction to First District decision in Mortgage Electronic Systems, Inc. v. Barnes, 406 Ill.App.3d 1 (1st Dist. 2010). Schostok, J.

No. 2012 IL App (2d) 110961  Wells Fargo Bank, N.A. v. McCluskey  Filed 11-2-12 (TJJ)


In this mortgage foreclosure action, the defendant, Katie McCluskey, appeals the trial court’s denial of her petition to vacate the foreclosure judgment. We reverse and remand for additional proceedings.

2 Appellate Cases Posted 11-01-12

1.  Traffic Court: Reversed: The act of rescinding is not simply to terminate. Both common usage and the operation of the term in legal proceedings impute an intention to undo an action so that it never existed.  NOTE: THIS DECISION IS CONTRARY TO APPELLATE DECISIONS IN THE FIRST & THIRD DISTRICTS.   Goldenhersh, J.

No. 2012 IL App (5th) 100584  People v. Elliott  Filed 11-01-12 (LJD)


Defendant, David K. Elliott, was issued a citation in Perry County for driving on a suspended driver's license. The circuit court entered a judgment of guilt. On appeal, defendant raises the issue of whether the conviction was proper given that his statutory summary suspension was rescinded. We reverse.

2.  Contract: Affirmed: Under the four corners rule of contract interpretation, "[a]ll conversations and parol agreements between the parties prior to the written agreement are so merged therein that they can not be given in evidence for the purpose of changing the contract or showing an intention or understanding different from that expressed in the written agreement."  In applying this four corners rule, a court initially looks to the language of the agreement alone. If the language is unambiguous, then the trial court interprets the agreement without resort to parole evidence.  However, if the court finds that the language of the contract is susceptible to more than one meaning, then an ambiguity is present, and parol evidence may be admitted to aid the trier of fact in resolving the ambiguity.   '[I]t is elementary that ordinarily a contract speaks from the day of its date, regardless of when it was executed and delivered.' "  "For a course of conduct to act as consent to a contract, it must be clear that the conduct relates to the specific contract in question."  " 'The parol evidence rule generally precludes evidence of understandings not reflected in the contract, reached before or at the time of its execution, that would vary or modify it[s] terms.' "  Even where the contract contains an express clause stipulating that "time is of the essence," Illinois courts will inquire into the situation of the parties and the underlying circumstances to determine whether a delay in performance resulted in a " 'material breach.' "   Pucinski, J.

No. 2012 IL App (1st) 101226  Asset Recovery Contracting, LLC v. Walsh Construction Company of Illinois Filed 11-01-12 (LJD)


2 The instant case arose from a multimillion dollar redevelopment of the Palmolive Building at 919 North Michigan Avenue, Chicago, Illinois, to convert the commercial office building into residential and retail condominiums. Defendant Walsh Construction Company of Illinois (Walsh) was the general contractor for the "core and shell" phase of the project, which generally entails removal of the interior finishes and mechanical and electrical and plumbing systems in preparation for build-out work. The trial court found that ARC breached the subcontract by leaving the project early and entered a judgment for damages in favor of Walsh in the amount of $337,020 on Walsh's counterclaim.  In its factual findings, the trial court found that the revised schedule changed the original completion date from late December 2003 to July 23, 2004. The trial court also found that "ARC received and reviewed the revised schedule and raised no objections to the cost projections or the impact that might result from the revised schedule." Thus, the court concluded that by accepting changes to the project schedule ARC waived its claims for additional compensation.  Also, the trial court considered the date of ARC's signature, and not the date listed on the contract, as the effective date of the subcontract.

2 Supreme Court Cases Posted 11-01-12

1. Unauthorized Practice of Law:  Appellate Court Affirmed reversing the Circuit Court:  This court has the inherent power to define and regulate the practice of law in this state.  Our rules are intended to safeguard the public from individuals unqualified to practice law and to ensure the integrity of our legal system.  The rule that a corporation must be represented by an attorney arises from the fact a corporation is an artificial entity that must always act through agents and there may be questions as to whether a particular person is an appropriate representative.  Only an individual representing the corporation itself can ascertain whether it is best for a corporation to pursue review of an administrative decision and invoke the appellate mechanism.  The per se nullity rule is unreasonable and that sanctions  for violating the rule against the unauthorized practice of law “should be proportioned to the gravity of the violation’s consequences.”  We hold there is no automatic nullity rule. Instead, the circuit court should consider the circumstances of the case and the facts before it in determining whether dismissal is proper. The circuit court should consider, inter alia, whether the nonattorney’s conduct is done without knowledge that the action was improper, whether the corporation acted diligently in correcting the mistake by obtaining counsel, whether the nonattorney’s participation is minimal, and whether the participation results in prejudice to the opposing party.  Burke, J., dissent by Karmeier, J., joined by Kilbride, CJ and Thomas, J.

No. 2012 IL  112040  Downtown Disposal Services, Inc. v. The City of Chicago  Filed 11-01-12 (LJD)


In this case, we must determine whether a complaint for administrative review filed by a corporation’s president, on behalf of the corporation, is a nullity because the president is not an attorney. For the reasons that follow, we conclude that the complaints are not void.

2.  Criminal Law: Appellate and Trial Court Affirmed: In reviewing a trial court’s ruling concerning whether a confession is voluntary, the trial court’s factual findings will be reversed only if those findings are against the manifest weight of the evidence.”  Ultimately, however, the trial court’s ruling on whether the confession was voluntary is subject to de novo review.   To determine the voluntariness of a confession, courts consider the totality of the circumstances, including such factors as the defendant’s age, intelligence, background, experience, education, mental capacity, and physical condition at the time of questioning.  Other factors include the duration and legality of the detention and whether there was any physical or mental abuse by the police. Threats or promises made by the police may be considered physical or mental abuse. Id. No single factor is dispositive, rather “[t]he test of voluntariness is whether the individual made his confession freely and voluntarily, without compulsion or inducement of any kind, or whether the individual’s will was overborne at the time of the confession.  The taking of a juvenile’s confession is a sensitive concern, and for this reason the greatest care must be taken to assure that the confession was not coerced or suggested.   The confession should also not be the product of adolescent fantasy, fright, or despair. Id. Illinois courts have recognized an additional factor not applicable in cases involving adults: the presence of a “concerned adult.”  This factor considers whether the juvenile, either before or during the interrogation, had an opportunity to consult with an adult  interested in his welfare.   In weighing this factor, courts also consider whether the police prevented the juvenile from conferring with a concerned adult and whether the police frustrated the concerned adult’s attempt to confer with the juvenile. However, a juvenile’s  confession or statement should not be suppressed merely because he was denied the opportunity to confer with a parent or other concerned adult before or during the interrogation.  Garman, J., dissent by Burke, J., joined by Freeman, J. and Theis, J.

No. 2012 IL  112362 People v. Murdock  Filed 11-01-12 (LJD)


Defendant, Germill D. Murdock, was convicted following a jury trial in the circuit court of Peoria County of first degree murder and aggravated battery with a firearm. Defendant’s conviction was affirmed on appeal. Defendant then filed a postconviction petition alleging trial counsel was  ineffective for failing to move to suppress statements defendant had made to police. Defendant, a juvenile, alleged his statements were the product of police coercion that rendered them involuntary. After conducting an evidentiary hearing, the trial court denied defendant’s petition. The  appellate court reversed and remanded to the trial court for a suppression hearing.Following the suppression hearing, the trial court denied defendant’s motion to suppress. The appellate court affirmed the denial of the motion to suppress. No. 3-07-0438 (unpublished order under Supreme Court Rule 23). Defendant appeals, arguing his statements were involuntary, primarily due to the absence of a concerned adult during his police detention. For the following reasons, we affirm the decisions of the trial court and appellate court.

Click on month for For Supreme Court & Appellate Opinions (with Summaries) posted during   October, 2012