Illinois Supreme and Appellate Court Case Summaries

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


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8 Appellate Court Cases Posted 1-27-10

1. Disability Benefits: Affirmed:  Section 10 of Public Safety Employee Benefits Act (820 ILCS 320/10 (West 2006) applies where fireman injured in training exercise and reasonable believed it was an emergency situation. Cunningham, J.

No.1-09-1133   Lemmenes v. Orland Fire Protection District  Filed 1-19-10 (LJD) 

This appeal arises from the grant of a motion for summary judgment in favor of the plaintiff, Brian Lemmenes, against the defendants Orland Fire Protection District and the Board of Trustees of the Orland Fire Protection District (collectively, Orland Fire) by the circuit court of Cook County. On appeal, Orland Fire argues that the circuit court erred in finding that the requirements for health insurance coverage benefits under section 10(b) of the Public Safety Employee Benefits Act were satisfied (820 ILCS 320/10(b) (West 2006)). For the following reasons, we affirm the ruling of the circuit court of Cook County.

2.  criminal Law: Affirmed: Effective assistance of counsel arguments  and rules discussed;  A defense counsel will not be deemed ineffective for failing to make a futile objection. "[B]loodhound" evidence is inadmissible to establish any factual proposition in a criminal proceeding. McLaren, J.

No.2-08-0314 People v. Holmes  Filed 1-20-10 (LJD) 

Defendant, Brandon R. Holmes, appeals his conviction of possession of a controlled substance with intent to deliver more than one gram but less than five grams of a substance containing cocaine (720 ILCS 570/401(c)(2) (West 2006)). On appeal, he argues that he was denied effective assistance of counsel because defense counsel failed to: (1) move to dismiss the indictment; and (2) properly object to the State's use of dog-tracking evidence. We affirm.

3.  Savings Clause/Statutes of Limitation and Repose: Reversed and Remanded: Permissible to refile case under savings clause within one year after nonsuit or dismissal for want of prosecution even if time of repose has expired.  Schostok, J.

No.2-09-0080 Jain v. Johnson  Filed 1-20-10 (LJD)

This case presents the question of whether the Illinois saving statute (735 ILCS 5/13--217 (West 2008)), which permits the refiling of certain dismissed actions within one year, creates an exception to the statute of repose for legal malpractice actions (735 ILCS 5/13--214.3(c) (West 2008)). For the following reasons, we hold that it does.

4.  Arbitration/Appellate Procedure: Affirmed in part and Appeal Dismissed in Part: Rule 307(a) provides for appeal of denial or granting injunction and order to compel (or not to compel) arbitration is injunctive in nature but Appellate Court can only review that order not all interlocutory orders in the case.  a waiver may occur where a party's actions are inconsistent with its right to seek arbitration and thus indicate an abandonment of the right.  The contractor had not waived its right to  compel arbitration. since that filing the mechanics lien was not inconsistent with seeking arbitration because the defendant demanded the filing under the Mechanics Lien Act. Hudson, J.

No.2-09-0854  Illinois Concrete-I.C.I., Inc. v. Storefitters, Inc.  Filed 1-20-10 (LJD)

Defendants Storefitters, Inc., and Tom Nesbitt, Jr., appeal the denial of a motion to compel arbitration in an action instituted against them by plaintiff, Illinois Concrete-I.C.I., Inc. Defendants also appeal the denial of their motion to dismiss counts in plaintiff's complaint, an order over which we lack jurisdiction. For the reasons that follow, we affirm the trial court's denial of the motion to compel arbitration and we dismiss the remainder of this appeal.

5.  Defamation: Affirmed: Fair Reportage privilege is analyzed; reliance on email from upon police department email- accuracy of reportage in issue not truth or falsity of the email. Schostok, J.

No. 2-08-0812  Eubanks v. Northwest Herald Newspapers    Filed 1-22-10 (LJD)

On June 15, 2007, the plaintiff, Carolene Eubanks, filed a complaint against the defendant, Northwest Herald Newspapers, alleging defamation and false light nvasion of privacy based on a short article indicating that she had been arrested and charged with retail theft and obstruction of justice. The defendant filed a motion for summary judgment, arguing that the publication could not be held defamatory under the fair-report privilege. On August 20, 2008, the trial court granted the defendant's motion for summary judgment. The plaintiff appeals from that order. On appeal, the plaintiff argues that the fair-report privilege should not apply because the subject publication was not "accurate and complete" and that a question of fact was raised as to whether the defendant abused or forfeited that privilege. We affirm.

6.  Civil Procedure/Franchisor Negligence/ Workers Compensation: Affirmed in Part and Reversed in Part:  A motion for dismissal under section 2--619(a)(9). Such a motion admits the legal sufficiency of the complaint, but asserts some affirmative matter as a defense. The phrase 'affirmative matter' refers to something in the nature of a defense that negates the cause of action completely or refutes crucial conclusions of law or conclusions of material fact contained in or inferred from the complaint. Duty of franchisors to protect employees of franchisees analyzed.  Arose out of employment element of Workers Comp. claim analyzed.  Burke, J.

No. 2-09-0026 & 2-09-0244 Lawson v. Schmitt Boulder Hill, Inc.  Filed 1-22-10 (LJD)

Plaintiff, Renae Lawson, filed a two-count complaint in the circuit court of Kendall County against defendants, Schmitt Boulder Hill, Inc. (Schmitt),1 and McDonald's Corporation (McDonald's). Plaintiff alleged that on December 18, 2005, she was a part-time employee at a restaurant owned by Schmitt and operated under a franchise agreement with McDonald's. Before she was able to enter the restaurant she was robbed, abducted, and assaulted.

7.  Freedom of Information Act: Affirmed: Burden is on the public body to establish any claim of an "exception" under section 7 of the FOIA and the defendant must provide a "detailed rationale" for the exception.  Survey is not an "audit". O'Malley, J.

No.2-09-0100  Rockford Police Benevolent & Protective Assn v. Morrissey  Filed 1-22-10 (LJD)

Defendants, Larry Morrissey, the mayor of Rockford (mayor), Chet Epperson, the chief of the Rockford police department (chief), and the City of Rockford Police Department (department), appeal the order of the circuit court of Winnebago County granting the cross-motion for summary judgment of plaintiff, the Rockford Police Benevolent and Protective Association, Unit #6, and denying defendants' cross-motion for summary judgment on plaintiff's Freedom of Information Act (FOIA) (5 ILCS 140/1 et seq. (West 2006)) request that seeks to compel defendants to disclose the results of a three-part survey1 conducted by Rockford College at the behest of the department.  Defendants argue that the survey should not be disclosed, under the theories that it is exempt as an audit (see 5 ILCS 40/7(1)(n) (West 2006)), as a personnel matter (see 5 ILCS 140/7(1)(b)(ii) (West 2006)), and under the self-critical analysis privilege. Defendants also argue that plaintiff is not entitled to an award of attorney fees or, alternatively, if plaintiff is entitled to attorney fees, then the trial court's fee award was excessive. We affirm.

8.  Criminal Law: Affirmed: Court's admonition that court would not be bound by sentencing recommendations if defendant did not appear at sentencing hearing sufficient.  Pope, J.

No. 4-08-0037  People v. Turner   Filed 1-22-10 (LJD)

In September 2007, defendant, Shawna M. Turner, pleaded guilty pursuant to a partially negotiated plea agreement to the offense of aggravated battery to a police officer. After accepting defendant's plea and entering judgment on the same, the trial court asked, during the same hearing, if part of the plea agreement was defendant's presence at the sentencing hearing. Defense counsel stated this was part of the plea agreement. The court then advised defendant if she was not present at the sentencing hearing there would be no agreement and the court could sentence her to up to seven years in the Illinois  Department of Corrections (IDOC). Defendant stated she understood. When defendant failed to appear at the sentencing  hearing, the trial court imposed the maximum seven-year sentence. Defendant appeals, arguing the trial court erred in adding a condition to its concurrence in the plea agreement after it had already accepted the plea. We affirm.

13 Appellate Court Cases Posted 1-25-10

1.  Criminal Law/Traffic:  Affirmed: Ample authority exists that the use of LIDAR to measure the speed of moving vehicles is based on generally accepted scientific principles. Therefore, the trial court did not err in overruling defendant's objection to the evidence.  McLaren, J.

No. 2-08-1006   People v. Mann  Filed 1-15-10  (RJC) 

Following a bench trial in the circuit court of Du Page County, defendant, Jack T. Mann, was found guilty of speeding (625 ILCS 5/11--601(b) (West 2006)). On appeal, he argues that the trial court erred in permitting the State to introduce evidence that the officer who ticketed defendant used a LIDAR1 device to measure the speed of defendant's vehicle. We affirm.

2.  Contracts/Pleadings: Vacated and remanded:  The written instrument upon which plaintiff's claim was founded was defendant's original credit card contract with Household Bank, which contract plaintiff then purchased from the bank. Plaintiff's failure to attach a copy of the credit card contract to the complaint, recite the terms of the contract within the complaint, or attach an affidavit showing that the document is inaccessible is grounds for dismissal.  Case remanded for further proceedings, premised upon plaintiff's compliance with Section 2--606 of the Code of Civil Procedure which provides that if a claim "is founded upon a written instrument, a copy thereof, or of so much of the same as is relevant, must be attached to the pleading as an exhibit or recited therein, unless the pleader attaches to his or her pleading an affidavit stating facts showing that the instrument is not accessible to him or her."  Jorgensen, J.

No. 2-08-0746  Velocity Investments v. Alston  Filed 1-15-10  (RJC) 

Plaintiff, Velocity Investments, LLC, filed suit against defendant, Gregory Alston, based on defendant's default on the terms of his credit card agreement. Defendant originally entered into a credit card agreement with Household Bank, whose interest in the debt was subsequently sold to plaintiff. The trial court entered judgment in favor of plaintiff. Defendant timely appeals. On appeal, defendant argues, inter alia, that plaintiff erred by failing to produce the original credit card contract, showing that defendant agreed to its terms and conditions. We agree with this contention and, accordingly, vacate and remand for further proceedings.

3.  Criminal Law:  Affirmed: The trial court adhered to Rule 431(b)'s requirement that each juror be asked, individually or in a group, whether that juror understood and accepted the Zehr principles, and each juror was given an opportunity to respond to specific questions concerning the principles.  Trial court did not err in allowing the State to call witness to the witness stand when it knew that he would invoke his fifth amendment right not to testify. The trial court determined that the State's motive was not a flagrant attempt to build its case from the privilege and that the evidence would not add critical weight to the State's case. The trial court did not abuse its discretion in allowing witness to invoke the fifth amendment on the witness stand. Bowman, J. 

No. 2-08-0208  People v. Calabrese  Filed 1-15-10  (RJC) 

Defendant, Michael J. Calabrese, was convicted of first-degree murder (720 ILCS 5/9--1(a)(3) (West 2004)) on January 18, 2008, after a jury trial. He was sentenced to 45 years' imprisonment plus an additional 25 years pursuant to the mandatory add-on for using a firearm (730 ILCS 5/5--8--1(a)(1)(d)(iii) (West 2004)). On appeal, defendant argues that: (1) the trial court failed to comply with Supreme Court Rule 431(b) (Official Reports Advance Sheet No. 8 (April 11, 2007), R. 431(b), eff. May 1, 2007); (2) there was insufficient evidence to prove his guilt beyond a reasonable doubt; (3) the trial court erred in knowingly allowing the jury to hear witness Patrick Calabrese invoke his fifth amendment privilege; and (4) his 70-year sentence was excessive given his mitigating factors. We affirm.

4.  Orders of Protection: Affirmed: The central inquiry in any proceeding to obtain an order of protection is whether the petitioner has been abused.  The trial court erred in ruling that neglect was a proper basis for the issuance of the plenary order of protection.  As a basis for an order of protection under the Act, neglect applies specifically to high-risk adults with disabilities.  Because that evidence was sufficient for a finding of abuse at the first hearing, it would also be sufficient for such a finding at the second hearing. Thus, while the trial court erred in issuing the plenary order of protection based on its finding that K.H. and J.H. were neglected, rather than abused, we presume that the evidence supporting the allegations made in both petitions was sufficient for a finding of physical abuse pursuant to section 103(14)(iii) of the Act (750 ILCS 60/103(14)(iii) (West 2008)). Therefore, although the basis of the plenary order of protection was not correctly noted, the trial court did not commit reversible error in issuing the plenary order of protection. McLaren, J. 

No. 2-09-0872  In re Marriage of Holtrof   Filed 1-19-10  (RJC) 

Respondent, Amy Holtorf, appeals from the orders of the trial court granting emergency and plenary orders of protection to her husband, petitioner Michael Holtorf, and their two children, K.H. and J.H., and denying her motion to vacate those orders of protection. We affirm.

5.  Real Estate/Property Taxes: Reversed and remanded: Illinois Property Tax Appeal Board's (the PTAB) order dismissing Aux Sable's property tax appeal was clearly erroneous. PTAB "has provided no factual basis for its decision to allow Aux Sable's motion to dismiss." O'Brien, J. with Schmidt, J. dissenting. McLaren, J. 

No. 3-08-0561   Minooka Community High School District No. 111 v. The Illinois Property Tax Appeal Board   Filed 1-12-10  (RJC) 

Petitioners Minooka Community High School District No. 111 and Minooka Community Consolidated School District No. 201 (collectively the School Districts) appeal a ruling of the Illinois Property Tax Appeal Board (PTAB), in which PTAB allowed Aux Sable to take a voluntary dismissal of its appeal of the Grundy County Board of Review’s (Board of Review) tax assessment of Aux Sable’s property for the year 2004, after the School Districts had successfully intervened in the proceedings and were in the process of obtaining their own valuation of the property. We reverse the decision of PTAB and remand the cause for further proceedings.

6.  Criminal Law: Affirmed: The court gave the jury an instruction regarding the offense that did not include the phrase "other than a firearm."  The evidence in this case was not closely balanced.  This error was not 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. Therefore, the trial court did not commit plain error by giving an improper jury instruction regarding count II.   The performance of the defendant's trial attorney fell below an objective standard of reasonableness by failing to object to the improper jury instruction for count II. However, because the evidence against the defendant was overwhelming, the attorney's failure to object was not so prejudicial that there was a reasonable probability that the outcome of the trial would have been different.  State did not fail to prove the elements of aggravated criminal sexual assault beyond a reasonable doubt.  Holdridge, J. with Wright, J. specially concurring.  

No. 3-08-0506   People v. Taylor  Filed 1-13-10  (RJC) 

In a three-count indictment, the State alleged that the defendant, Toola O. Taylor, Sr., committed criminal offenses on July 18, 2006. In count II, the State charged him with aggravated criminal sexual assault. Before the jurors began their deliberations, the court gave them, among other instructions, an outdated instruction for count II, which did not specify that the dangerous weapon was to be one other than a firearm. The jury found that the defendant had committed both criminal sexual assault and aggravated criminal sexual assault, as charged in count II. Additionally, pursuant to a special verdict form, the jury found that the defendant had not committed aggravated criminal sexual assault while armed with a firearm. The court sentenced the defendant to 32 years of imprisonment, based on count II alone. On appeal, the defendant argues that, regarding count II: (1) it was plain error for the court to fail to instruct the jury that the dangerous weapon was to be one other than a firearm; (2) his attorney provided ineffective assistance by failing to object to the improper jury instruction; and (3) the State did not prove the elements of the offense beyond a reasonable doubt. We affirm. 

7.  Foreclosure/Mechanic's Liens: Affirmed in part and reversed in part, and the cause is remanded: The first issue for consideration is whether the trial court erred in apportioning the sheriff’s sale proceeds. As the sale proceeds were insufficient to satisfy the liens and the mortgage in full, the trial court employed the proportionality analysis, crediting Edon and Eagle with their share of the value of the improvements and crediting LaSalle its proportional share of the value of the land. The trial court correctly allocated the sheriff sale proceeds pursuant to section 16 of the Illinois Mechanics’ Lien Act. The next issue is whether the trial court erred when it denied LaSalle’s request for attorney fees.  The award of attorney fees is mandatory under the statute and therefore we hold that the trial court erred in denying LaSalle’s request for payment of its attorney fees. O'Brien, J. with Carter, J. concurring in part and dissenting in part and with Schmidt, J. specially concurring.  

No. 3-08-0114   LaSalle National Bank v. Cypress Creek   Filed 1-15-10  (RJC) 

Plaintiff-appellee-cross-appellant LaSalle Bank National Association filed this action to foreclose a mortgage it held on a parcel of real estate that was being developed for senior apartments. Defendants-appellants-cross-appellees Edon Construction Co. and Eagle Concrete filed mechanic’s liens for work they had done on the apartment buildings. The property was sold pursuant to a sheriff’s sale, and in allocating the sale proceeds, the trial court apportioned the funds between LaSalle as mortgagee and Edon and Eagle as mechanic’s lien claimants, and subrogated LaSalle to the position of mechanic’s lien claimant for various costs it funded during construction. On appeal, Edon and Eagle challenge the allocation and LaSalle cross-appeals the trial court’s denial of its request for attorney fees. We affirm in part, reverse in part, and remand.

8. Traffic Law: Affirmed in part and reversed in part: Whee three of four defendants in DUI cases strictly complied with provisions of Supreme Court Rule 505, trial courts did not abuse their discretion in dismissing, with prejudice, traffic tickets against defendants, including DUIs, where cases did not appear in court within 14-60 period in Rule 504. Lytton, J. (Schmidt, J., dissenting in part).

Nos. 3-08-0770, 3-08-0771, 3-08-0793, 3-09-0071 & 3-09-0072 (Consol.)  People v. Ziobro  Filed 1-13-10 (TJJ)

Defendants Todd Wambsganss, James Ziobro, Michael Lemoine and Robert Shanahan were issued citations for driving under the influence and other traffic violations. The first appearance dates listed on their citations were beyond the prescribed period set forth in Supreme Court Rule 504 (166 Ill. 2d R. 504). At their first appearances, defendants filed motions to dismiss. The trial court granted the motions and dismissed the charges against defendants with prejudice. We affirm in part and reverse in part.

9. Election Law: Affirmed: Judicial candidate for subcircuit judgeship within a judicial circuit must be a resident of the subcircuit at the time the candidate files petitions to be a candidate for that office. Carter, J. (Wright, J., dissenting)

No. 3-09-1031  Goodman v. Ward  Filed 1-14-10 (TJJ)

Daniel Goodman petitioned the Will County Officers Electoral Board (Board), objecting to listing Chris Ward as a candidate on the ballot in the primary for the office of Circuit Court Judge of the Twelfth Judicial Circuit, Fourth Subcircuit (subcircuit). The Board denied Goodman's petition. On review, the Will County circuit court reversed the Board's decision. We reverse the Board's decision and affirm the circuit court's ruling.

10. Traffic Law: Reversed and remanded: Trial court suppression of alcohol testing results on defendant's urine, collected by a phlebotomist at hospital and thus not in strict compliance with administrative regulation, was remanded for a hearing to ascertain whether collection constituted substantial compliance. Lytton, J. (Wright, J., dissenting).

No. 3-09-0081  People v. Henry  Filed 1-19-10 (TJJ)

While driving her automobile, defendant, Delores Henry, struck a pedestrian. Police arrested defendant for various traffic violations and transported her to a hospital to have her blood and urine tested. Based on the results of her urine test, defendant was charged with aggravated driving under the influence of alcohol (625 ILCS 5/11-501(d) (West 2006)). Defendant filed a motion to suppress the results of her urine test. The trial court granted the motion. We reverse and remand.

11. Construction Law: Reversed and remanded: Plaintiff contractor's ignorance of need to provide homeowner with a consumer brochure and a written signed work order did not bar plaintiff's action to foreclose a mechanic's lien and for breach of contract, where plaintiff performed work in compliance with oral agreement, and trial court grant of summary judgment to defendant was error. McDade, J. (Schmidt, J., specially concurring, and Lytton,  J., dissenting)

No. 3-08-0237  Fandel v. Allen  Filed 1-14-10 (TJJ)

Plaintiff, David Fandel, doing business as Fandel Construction, performed construction work for defendant, Tiffany Allen, on defendant’s home. After the project was complete, plaintiff recorded a “claim for lien” and commenced suit to foreclose the lien after defendant stopped payment on the check she tendered in payment of the services. Plaintiff now appeals from the trial court’s granting of summary judgment in favor of defendant. We reverse and remand.

12. Parental Rights Law: Affirmed:  Trial court did not err in denying mother right to call child who was subject  of  termination of parental rights proceeding to ascertain child's wishes regarding termination of parental rights, where trial court properly concluded that forcing child to testify was potentially injurious to child in light of all facts of the case. Carter, J.

No. 3-09-0788 & 3-09-0789 (Consol.)  In re A.W., Jr.  Filed 1-13-10 (TJJ)

The respondent-mother, P.W., appeals from the trial court's decision to bar her from calling her 15-year-old son, A.W., Jr., as a witness at the best interest hearing. The respondent argues that the trial court's decision to bar A.W., Jr.'s testimony violated her due process rights. We affirm.

13. Administrative Law: Vacated: Trial court grant of mandamus relief to plaintiffs who complained of administrative decision relating to medical assistance under Public Aid Code was required to be vacated, as relief to plaintiffs was only proper under Administrative Review Law. Burke, J.

No. 2-09-0013  Guerrero v. Gardner  Filed 1-15-10 (TJJ)

Plaintiffs, Margarita Guerrero and Deloris McCoy, applied separately to the Illinois Department of Human Services (Department) for medical assistance. The Department denied both applications on the ground that neither met the statutory criteria. Each plaintiff filed an administrative appeal, and the Department scheduled both appeals for December 7, 2006. Before the hearing, Guerrero's representative submitted a written request to appear by telephone, and McCoy's representative asked for a postponement pending receipt of additional medical records. The Department did not grant either request. When plaintiffs did not appear for their hearings, the Department dismissed the appeals as abandoned. The time for petitioning for administrative review passed, and plaintiffs filed a complaint for mandamus in the circuit court. The trial court's grant of mandamus relief was thereafter vacated by the Appellate Court where relief was only available to plaintiffs under the Administrative Review Law.

8 Supreme Court Cases Posted 1-22-10

1.  Post Conviction Petitions: Appellate and Trial Court Affirmed: No post conviction relief  because defendants alleged not being informed of Mandatory Supervised Release  in addition to sentences.  Fitzgerald, CJ.

No.105989 & 106592 Cons.  People v. Morris   Filed 1-22-10 (LJD) 

In this consolidated appeal, defendants, James Morris and Jesse Holborow, contest the first-stage dismissals of their respective postconviction petitions. Defendant Morris entered a negotiated plea of guilty in  he circuit court of Cook County to two counts of aggravated criminal sexual assault in exchange for concurrent sentences of 30 years. Defendant Holborow entered a negotiated plea of guilty in the circuit  court of Livingston County to home invasion with great bodily harm to the victim, theft, and criminal trespass to a vehicle in exchange for the dismissal of four other charges and a 16- year term of  imprisonment with concurrent terms of 3 years and 364 days. In their pro se postconviction petitions, defendants each asserted that they were not informed that they would be required to serve terms of  mandatory supervised release (MSR) in addition to their sentences and, therefore, did not receive the benefit of their negotiated plea agreements. The appellate court affirmed in both matters, finding that  defendants’ postconviction claims were frivolous and patently without merit, as the records showed that defendants received admonishments that substantially complied with Supreme Court Rule 402 (177 Ill.  2d R. 402) and otherwise satisfied due process. Morris, No. 1–06–2036 (unpublished order under Supreme Court Rule 23); Holborow, 382 Ill. App. 3d 852. We granted leave to appeal and consolidated defendants’ cases. 210 Ill. 2d R. 315. For the reasons that follow, we affirm the judgment.

2.  Speedy Trial Act: Appellate Court reversed in Part and affirmed in part, Trial Court Reversed: When incarcerated, for speedy trial act demand to be effective, defendant must make clear and unequivocal demand indicating what charges the demand applies to and serve it on the state's attorney plus other requirements.    Karmeier, J.

No.106496  People v. Sandoval  Filed 1-22-10 (LJD)

Defendant, Jose J. Sandoval, was charged in the Du Page County circuit court under two separate case numbers with multiple traffic offenses arising out of three separate traffic stops. The charges included  three counts of driving under the influence of alcohol (DUI). After he was incarcerated in the Illinois Department of Corrections (DOC) for a Cook County DUI, defendant filed a form document entitled  “Demand for Speedy Trial and/or Quash Warrant,” citing section 103–5(b) of the Code of Criminal Procedure of 1963 (725 ILCS 5/103–5(b) (West 2004)) and section 3–8–10 of the Unified Code of  Corrections (the Code) (730 ILCS 5/3–8–10 (West 2004)), and noting as charge pending, “Du Page County D.U.I.” Defendant did not specify the case to which the demand was intended to apply. When defendant was not brought to trial on any charge within 160 days thereafter, defendant filed a motion to dismiss in one of the pending cases. After gaining dismissal of those charges, he filed a second motion  o dismiss in the other case, succeeding in having those charges dismissed as well. The State appealed. The appellate court, with one justice dissenting, affirmed the dismissal of all DUI charges, but reversed as  to non-DUI charges arising from the same incidents. 381 Ill. App. 3d 142. We reverse the appellate court as to the dismissal of the DUI charges, and otherwise affirm.

3.  Condemnation: Appellate and trial court affirmed: Tax increment financing bondholders not entitled to value for loss due to eminent domain action.  Freeman, J.

No.  106805   City of Chicago v. Prologis  Filed 1-22-10 (LJD)

The circuit court of Cook County denied defendant and intervening petitioners’ counterclaim for inverse condemnation. The appellate court affirmed the circuit court’s denial of the counterclaim (383 Ill. App.  3d 160), and we granted defendant and intervening petitioners’ leave to appeal. 210 Ill. 2d R. 315. For the reasons that follow, we affirm the judgment of the appellate court.

4.  Firefighters Common Law Rule: Appellate and Trial Courts Affirmed:  A retroactive change in the law that imposes a new duty is “prohibited as a violation of the due process clause of the Illinois  Constitution, and the legislature is without authority to enact such a law even if that is its express intention.   Burke, J.

No. 107192  Lazenby v. Mark's Construction   Filed 1-22-10 (LJD)

In the early morning hours of August 30, 2001, a fire broke out in
the basement of a Park Ridge, Illinois, residence which was under construction. Firefighters Wedge C. Lazenby (Lazenby) and Derek R. Decker (Decker) (collectively hereinafter referred to as plaintiffs)responded to the fire. While attempting to locate the source of the fire, Lazenby fell through an unprotected floor opening to the cement basement below and was severely injured. Decker was injured when he fell from a ladder while attempting to rescue Lazenby. Plaintiffs filed suit in the circuit court of Cook County against Mark’s Construction, Inc. (Mark’s Construction), the general contractor working on the  home. The trial court entered summary judgment against Decker, finding that Mark’s Construction had no duty to prevent Decker’s injuries. Following a trial on Lazenby’s claims, the trial court entered  judgment on the jury’s general verdict for Mark’s Construction. Both plaintiffs appealed, and the appellate court affirmed the trial court’s judgment. No. 1–06–2969 (unpublished order under Supreme Court   Rule 23). The issues presented in this appeal are: (1) whether section 9f of  the Fire Investigation Act (Act) (425 ILCS 25/9f (West 2004)) applied retroactively to Decker’s claims; and (2) whether  the trial court erred in failing to enter a judgment notwithstanding the verdict (judgment n.o.v.) or order a new trial for Lazenby. For the reasons that follow, we affirm the appellate court.

3.  Post Conviction: Appellate and Trial Court Affirmed:  In this decision, the supreme court rejected this untimeliness claim. Although the supreme court was not entirely comfortable with the delay which had occurred, it noted that the delay was in part due to the difficulty of obtaining a Tamil interpreter and, also, was for the benefit of the offender, who was not prejudiced. The supreme court declined the suggestion to set a time limit for giving admonitions on recharacterization. It held that no error had occurred and affirmed the results reached below.  Fitzgerald, CJ.

No. 107441 People v. Swamynathan  Filed 1-22-10 (LJD)

Defendant, Ramesh K. Swamynathan, entered a plea of guilty but mentally ill to one count of first degree murder and was sentenced to 20 years in prison. Nearly two years later, defendant filed a pro se motion to withdraw his guilty plea and vacate his sentence, asserting that he was unfit to enter the guilty plea, rendering his plea involuntary. The circuit court of Lake County recharacterized defendant’s  motion as a postconviction petition and summarily dismissed the petition as patently without merit. Defendant appealed, asserting that the trial court summarily dismissed his petition more than 90 days after the  day it was docketed, in violation of the provisions of the Post-Conviction Hearing Act (Act) (725 ILCS 5/122–1 et seq. (West 2006)). The appellate court affirmed. 385 Ill. App. 3d 434. We granted defendant leave to appeal (210 Ill. 2d R. 315), and for the reasons that follow, we affirm.

6.  Workers Compensation: Appellate Court Reversed: Circuit Court and Commission Affirmed:  Entitlement to temporary total disability benefits is a completely separate issue from, and may not be conditioned on, the propriety of the discharge.  Burke, J.

No. 107852  Interstate Scaffolding v. The Workers' Compensation Commission  Filed 1-22-10 (LJD)

In this appeal we are asked to consider whether an employer’s obligation to pay temporary total disability (TTD) workers’ compensation benefits to an employee who was injured in the course of his  employment ceases when the employer terminates the employee for conduct unrelated to the injury. For reasons that follow, we hold that when an employee who is entitled to receive workers’ compensation  benefits as a result of a work-related injury is later  terminated for conduct unrelated to the injury, the employer’s obligation to pay TTD workers’ compensation benefits continues until -2- the employee’s  medical condition has stabilized and he has reached maximum medical improvement.

7.  Post Conviction Petition: Appellate Court Decision Vac. and Remanded for Hearing: Issue of appealibilty of trial court's order on filing of second post conviction petition. Karmeier, J.

No. 108133 People v. Tidwell   Filed 1-22-10 (LJD)

At issue in this appeal is whether a motion or request is required to obtain a ruling allowing or denying leave to file a successive postconviction petition under section 122–1(f) of the Post-Conviction Hearing  Act (Act) 725 ILCS 5/122–1(f) (West 2006)), and whether a ruling rendered in the absence of a motion or request is subject to review in the appellate court. We hold that the circuit court is not obliged to  rule in the absence of a motion or request, but that it may do so where documents submitted by a defendant supply an adequate basis for a ruling on the threshold cause-and-prejudice question, and when the  circuit court has ruled, its determination is subject to review in the appellate court. When Tidwell appealed, however, the appellate court refused to reach the merits because no motion or request for leave to file had been made.   In this decision, the supreme court held that a circuit court may, if it chooses, reach the issue of whether leave to file should be granted sua sponte. Statute does not specifically require a motion or request for this determination if the circuit court elects on its own to make it (although the burden remains on the postconviction petitioner to show that he can meet the “cause and prejudice” test). Therefore, the circuit court had not generated an order which was not reviewable, and the appellate court should have accepted Tidwell’s appeal.

8.  Criminal Law? Assessment of Costs: Appellate and Trial Court reversed: Preliminary Hearing  means probable cause hearing, not bail hearing.  Thomas, J.

No. 108297  People v. Smith   Filed 1-22-10 (LJD)

At issue is whether a State’s Attorney may recover a statutory preliminary examination fee (55 ILCS 5/4–2002.1(a) (West 2008)) when a defendant receives a bail hearing but not a hearing to determine  probable cause. We hold that the preliminary examination fee is available only when there has been a probable cause hearing.

11 Appellate Court Cases Posted 1-15-10

1.  Criminal Law: Reversed: Insanity Defense analyzed; Defendant must prove by preponderance mental illness, then burden shifts to state to prove beyond reasonable doubt before the fact finder considers insanity defense.  Expert testimony may be entirely rejected by the trier of fact if he or she concludes a defendant was sane based on factors such as: whether lay  testimony is based on observations made shortly  before or after the crime; the existence of a plan for the crime; and methods undertaken by the defendant to prevent detection.   Gordon, J.,  McBride, J. dissents.

No.  1-08-0657  People v. Kando   Filed 12-31-09 (LJD)

Defendant, Amir Kando, was arrested and charged with aggravated battery and attempt murder of his neighbor, Jason Burley. At his bench trial, defendant raised the insanity defense pursuant to section 6-2  of the Criminal Code of 1961 (Code) (720 ILCS 5/6-2 (West 2002)). The trial court found defendant guilty but mentally ill and subsequently sentenced him to 15 years’ imprisonment.  Defendant finally  contends that even if his conviction is affirmed, we should nevertheless remand for a new sentencing hearing because the trial court abused its discretion when it sentenced him to 15 years’ imprisonment, a  sentence nine years above the statutory minimum.1 For the reasons set forth below, we reverse.

2.  Civil Procedure/Appellate Procedure: Affirmed:  Failure to appeal judgment within 30 deprives Appellate Court of jurisdiction; A void order can be attacked at any time so court only had jurisdiction to consider whether judgment was void;  A void judgment is one that is entered by a court without jurisdiction over the parties or the subject matter or by a court that lacks the inherent power to make or enter the order;  an order will not be rendered void nor will the court lose jurisdiction merely because of an error or impropriety in the court’s determination of the facts or law.    Theis, J.

No.  1-09-0232 Government Employees Insurance Company v. Hersey Filed 1-12-10 (LJD)

This case arises out of a supplemental citation proceeding brought by plaintiff, Government Employees Insurance Company (GEICO), against third-party respondent, American Access Casualty Company  AACC), to discover assets and satisfy a judgment in an underlying negligence action that was entered in favor of GEICO against AACC’s insured, Aaron Hersey. The circuit court ultimately entered a  judgment in favor of GEICO and against AACC and subsequently denied AACC’s motion to vacate the judgment. On appeal, AACC contends that the judgment is void and that the court erred in denying its  otion to vacate the judgment. For the following reasons, we affirm the judgment of the circuit court.

3.  Insurance Law:Affirmed: Equitable contribution between insurance carriers defined and analyzed;  when two insurers cover "separate and distinct risks," equitable contribution does  not apply;  other insurance clauses do not apply because of liability due to equitable contribution.   McLaren, J.

No.  2-08-0781  American States Insurance v. CFM Construction   Filed 1-12-10 (LJD)

American States Insurance Company (American) appeals from part of a judgment of the trial court denying its motion for summary judgment and granting summary judgment to CFM Construction Company  (CFM) and Michigan Mutual Insurance Company (Michigan). The trial court ruled that American was required to pay Michigan half of the amount of a settlement Michigan paid under a policy it issued to a  subcontractor, International Decorators, that worked for a general contractor, CFM. Michigan cross-appeals from part of the same judgment denying it and CFM attorney fees, costs, and prejudgment  interest. On cross-appeal, Michigan argues that (1) the trial court erred by failing to award it and CFM attorney fees and costs; and (2) the trial court erred by failing to award it and CFM prejudgment interest. We affirm.

4.  Immunity Act: Affirmed: no duty of care to individual members of the general public to provide governmental services, such as police and fire protection.  Duty runs to general public at large, not an individual.   Holdridge, J.

No.3-08-0776  Donovan v. The Village of Ohio   Filed 1-11-10 (LJD)

James E. Donovan died in a fire at Turner's Tap in Walnut, Illinois. His widow and the administrator of his estate, filed a lawsuit against four defendants alleging, inter alia, an electronic equipment failure of the 911 emergency response system. Her claims against the County were dismissed, and she settled her claims against Turner's Tap. The Village and the Board then filed motions for summary judgment, which were granted. Judy appeals from the order granting those motions.

5.  Criminal Law: Affirmed: Failure to advise jury of all of Rule 431 principles does not require automatic reversal; court's failure corrected by defense counsel's admonition and by finding that no rational jury would have acquitted defendant.  Pope, J.

No.  4-08-0841 People v. Chester   Filed 1-12-10 (LJD)

In October 2007, defendant, Gregory J. Chester, was indicted on three counts of aggravated battery (720 ILCS 5/12- 4(a), 124(b)(6) (West 2006)) and one count of resisting a peace officer (720 ILCS  5/31-1(a-7) (West 2006)). Following a jury trial, defendant was convicted and sentenced to 12 years' imprisonment for aggravated battery.  We affirm.

6.  Juvenile Justice: Reversed and Remanded:  Before sentencing as an adult, juvenile must be adjudicated under the Act;  In this case, supplemental opinion deals with whether defendant should be released on bail after remand. Pope, J.

No.   4-08-0847 People v. King    Filed 11-09-09 (LJD)  Supplemental filed 1/7/10

Counsel for defendant, following the filing of this court's opinion in this cause, filed a "Motion for Release Pursuant to Supreme Court Rule 604(a)(3), or, in the Alternative, Admission to Bail, Pending  Resolution of the State's Appeal."   This appeal covered by Rule 613(c).

7.   Medical Negligence: Affirmed: A tactical decision not to object waives results in procedural forfeiture;  Denial of motion for mistrial reviewed under clear abuse of discretion standard;  Court did not abuse discretion by admitting literature appended to hospital policy and procedures.  Steigman, J.

No.   4-09-0249  Lovell v. Sarah Bush Lincoln Health Center   Filed 1-12-10 (LJD)

In June 2005, plaintiff, Clinton Dean Lovell, sued defendant, Sarah Bush Lincoln Health Center (Health Center), for medical malpractice, claiming that the Health Center's negligence following his August 2003  surgery caused him severe and permanent injury. Following a September 2008 trial, a jury returned a verdict in Lovell's favor and awarded him $2,378,258. Because we (1) conclude that the Health  Center forfeited any challenge to Lovell's opening statement and (2) disagree that the court abused its discretion, we affirm.

8.  Administrative Review:Affirmed: Questions of law in agency decision are reviewed de novo; Code to be liberally construed in favor of employee but Board has fiduciary duty to all participants and beneficiaries of fund;  voluntary withdrawal of application for line of duty pension was final 35 days after Board allowed withdrawal;   Pope, J.

No.  4-09-0280 Philpott v. The Board of Trustees of the City of Charleston Firefighters' Pension Fund   Filed 1-12-10 (LJD)

In April 2009, the circuit court filed an order denying plaintiff John Philpott's complaint for administrative review. Plaintiff appeals, arguing the court erred in confirming the September 2008 decision of  defendant, the Board of Trustees of the City of Charleston Firefighters' Pension Fund (Board), which set a commencement date of February 1, 2008, for plaintiff's "not-on-duty" disability pension. Plaintiff  asks this court to reverse the judgment of the circuit court and remand this case for the Board to enter a commencement date of June 1, 2005. We affirm.

9.  Criminal Law:Affirmed: No basis to believe that defendant doing anything criminal which warranted search; Officers providing security for execution of search warrant did not have reason to believe defendant was part of activity going on in the house.  Mere hunch is insufficient.   Knecht, J.

No.  4-09-0338 People v. Chestnut Filed 1-12-10 (LJD)

In January 2008, the State charged defendant, Warren D. Chestnut, with one count of possession of a controlled substance (720 ILCS 570/402(c) (West 2008)) and one count of possession of a controlled  substance with intent to deliver (720 ILCS 570/401(c) (West 2008)). Later that month, defendant filed a motion to quash arrest and suppress evidence, alleging defendant's search and seizure were illegal  because the arresting officers lacked a reasonable suspicion of criminal activity. The trial court granted the motion, finding the officers had no reasonable suspicion defendant was engaged in criminal activity when he approached a residence during execution of a search warrant.  On appeal, the State argues the trial court erred by quashing defendant's arrest and suppressing evidence. We disagree and affirm.

10.  Arbitration:Affirmed in part, Reversed in part and Remanded: Ce novo standard of review if no evidenciary hearing or finding of fact rendered by trial court in order compelling arbitration;  non parties to a contract can not compel arbitration;  LLC is separate entity and must be a party to the contract to enforce arbitration clause;    Spomer, J.

No.  5-09-0145   Trover v. 419 OCR   Filed 1-12-10 (LJD)

The defendants–419 OCR, Inc., O'Fallon Development Group, LLC (O'Fallon Group), Mark Halloran, and Steve Macaluso–appeal the March 30, 2009, order of the circuit court of St. Clair County  denying their motion to compel arbitration under the Illinois Uniform Arbitration Act (710 ILCS 5/1 et seq. (West 2008)) and the Federal Arbitration Act (9 U.S.C. §§1 through 16 (2006)). For the following  reasons, we affirm in part, reverse in part, and remand for proceedings not inconsistent with this opinion.

Torts/Workers Compensation: Reversed and Remanded: Issue of whether plaintiff's common law claim was barred under Workers Compensation Act; Mere acceptance of unsolicited benefits offered by an employer is insufficient to bar a plaintiff's common law claim.   Goldenhersh, J.

No.   5-08-0446  Reed v. White   Filed 1-12-10 (LJD)

Plaintiff, Regina M. Reed, filed a two-count complaint against defendants, Richard White, as the executor of the estate of Nelda Harris, doing business as Harris Farms, and Ronald D. Reed, plaintiff's  husband, after plaintiff was involved in an accident with a John Deere tractor and farm implement that was being driven by Ronald as a part of his employment with Harris Farms. Plaintiff was a part-time  employee of Harris Farms, but she was not scheduled to work on the day of the accident.Defendants admitted that Ronald's operation of the tractor and implement without an escort or lead vehicle was negligent; however, defendants asserted that plaintiff was an employee at the time of the  accident and was limited by the exclusivity provisions found in the Workers' Compensation Act (Act) (820 ILCS 305/1 et seq. (West 2002)). Accordingly, defendants filed a motion to dismiss pursuant to  section 2-619 of the Code of Civil Procedure (Code) (735 ILCS 5/2-619 (West 2006)), which the trial court granted. The issue raised in this appeal is whether the trial court erred in dismissing plaintiff's  complaint with prejudice pursuant to section 2-619 of the Code. We reverse and remand.

10 Appellate Court Cases Posted 1-13-10

1.  Insurance Law: Reversed: Excess clauses discussed and Targeted tender to Insurance carriers discussed;  equitable subrogation elements analyzed;  Waiver arises from an affirmative act, is consensual, and consists of an intentional relinquishment of a known right and can be express or implied from conduct.  Duty of insurer to allocate settlement funds to primary or excess policy in order to seek equitable subrogation; A party may make inconsistent statements of fact in a pleading when the party is in doubt as to which statement is true. However, when the nature of the  statements are such that the plaintiff must know which statement is true, inconsistent pleading is improper.  The target tender rule provides an insured covered by multiple concurrent policies with the paramount right to choose which insurer will defend and indemnify it with respect to a specific claim. A target tender is not negated merely by an expressed desire to keep the deactivated insurer on notice as standby coverage in the
event that the selected insurer refuses the tender or in the event that the selected primary coverage has been exhausted.   Theis, J.

No. 1-07-2195 & 1-07-2258 Con. Chicago Hospital Risk Pooling Program v. Illinois State Medical Inter-Insurance Exchange Filed 12-22-09(LJD)

Plaintiff and counter defendant, Chicago Hospital Risk Pooling Program (CHRPP), brought an action against defendant and counterplaintiff, Illinois State Medical Inter-Insurance Exchange (ISMIE), under a theory of equitable contribution seeking to recover a portion of a settlement payment it made on behalf of a physician in an underlying medical malpractice suit. ISMIE filed a counterclaim seeking to recover its defense costs in defending the physician. Subsequently, CHRPP amended its complaint seeking reimbursement under both theories of equitable contribution and equitable subrogation. Ultimately, both parties filed cross-motions for summary judgment on CHRPP’s claims and ISMIE filed a motion for summary judgment on its counterclaim.  For the reasons that follow, we reverse the judgment of the circuit court granting summary judgment in favor of CHRPP on its equitable subrogation claim, and reverse that portion of the judgment of the circuit court granting summary judgment in favor of ISMIE on its counterclaim for only one-half of its defense costs.

2.  Administrative Review: Reversed and Remanded: Village may have right to intervene in hearing but village attorney's participation in the hearing was an abuse of discretion requiring reversal.   Theis, J.

No. 1-08-1212  Williams v. Board of Trustees of the Morton Grove Firefighters' Pension Fund   Filed 12-22-09(LJD)

Plaintiff, Darren Williams, filed an application for a line-of-duty disability pension with defendant, the Board of Trustees of the Morton Grove Firefighters’ Pension Fund (Board), pursuant to section 4-110 of the Illinois Pension Code (the Pension Code). 40 ILCS 5/4-110 (West 2006). Plaintiff subsequently amended his application to include a claim for a not-in-duty disability pension pursuant to section 4-111 of the Pension Code.  The Board voted to deny plaintiff a line-of-duty pension, but granted him a not-in-duty disability pension pursuant to Section 4-111. Thereafter, plaintiff filed a complaint for administrative review in the Circuit Court of Cook County. The Circuit Court affirmed the Board’s decision. Plaintiff filed this timely appeal in which he argues that: (1) the Board’s denial of a line-of-duty pension was against the manifest weight of the evidence; (2) allowing the four  village representatives to participate in the adjudication of his application after the Village intervened violated his right to due process; and (3) the Board abused its discretion when it permitted the Village to intervene in plaintiff’s pension hearing. For the following reasons, we vacate the decision of the Board and remand with instructions.

3.  Criminal Law: Affirmed: de novo review of the ultimate question of whether evidence should be reviewed; A confession given by a defendant following an illegal arrest may be admissible if it insufficiently attenuated from any illegality; Whether the confession was obtained by exploitation of the illegal arrest or was obtained “by means sufficiently distinguishable to be purged of the primary taint” from the illegal arrest. Four factors of attenuation to be considered analyzed and discussed.  O'Mara Frossard, J.

No. 1-08-2832  People v. Salgado   Filed 12-17-09(LJD)
 
We are asked to decide whether incrimination statements made by defendant following an illegal arrest are sufficiently attenuated from the illegality of the arrest to render the statements admissible. Following a bench trial, Paul Salgado was convicted of the first degree murder of Julio Rodarte. He was sentenced to 30 years’ imprisonment for first degree murder with a 25- year enhancement for causing death with the use of a firearm. Defendant appealed. People v. Salgado, No. 1-03-1753 (2006) (unpublished order under Supreme Court Rule 23) (Salgado I). We vacated the convictions and sentences on appeal after finding that the police lacked probable cause to arrest defendant. Salgado I, slip op. at 52. We remanded the case to the trial court to hold an attenuation hearing. Salgado I, slip op. at 52. On remand, the trial court held defendant’s incriminating statements made after arrest were admissible despite the illegal arrest and reinstated defendant’s conviction and sentences.

4.  Administrative Review: Affirmed: cause for discharge by Board analyzed; Discharge for excessive unexcused absences permissible;   O'Mara Frossard, J.

No. 1-08-3415 Marzano v. The Cook County Sheriff's Merit Board   Filed 12-17-09(LJD)

In this administrative review action, plaintiff, Michelle Marzano, appeals from a decision of the circuit court affirming the January 24, 2008, decision of defendant Cook County Sheriff’s Merit Board and its members (collectively, the Board) that plaintiff be discharged from employment, effective July 11, 2006. We affirm.

5.  Criminal Law: Affirmed: The arbitrary and unreasonable disparity between the sentences of similarly situated codefendants is impermissible.  However, fundamental fairness is not violated simply because one defendant is sentenced to a greater term than another.  Hutchinson, J.

No. 2-06-1236 People v. Stroup  Filed 01-08-10(LJD)

At issue in this appeal is whether the concurrent 25-year sentences of defendant, Kenneth H. Stroup, for armed robbery (720 ILCS 5/18--2(a) (West 2002)) and home invasion (720 ILCS 5/12--11(a)(6) (West 2002)) are grossly disparate to the concurrent 15-year sentences imposed on defendant's codefendant, Damon Jones, for the same offenses. Because Jones was sentenced on additional convictions, we determine that defendant and Jones are not similarly situated. Thus, we affirm. 

6. Criminal Law: Reversed and remanded: In post-conviction petition, defendant did not have a constitutional right to be present at jury instruction conference, but his claim that his attorneys were ineffective for failing to secure his agreement regarding "all or nothing" strategy and waiving right for jury to be instructed on second degree murder did state "gist" of a constitutional claim in light of evidence against defendant at trial, and trial court's dismissal of that claim was erroneous. Hudson, J.

No. 2-07-1276  People v. DuPree  Filed 1-6-10 (TJJ)

Defendant, Maurice DuPree, appeals the summary dismissal of his petition for relief under the Post-Conviction Hearing Act (Act) (725 ILCS 5/122--1 et seq. (West 2006)) from his conviction by a jury of first-degree murder (720 ILCS 5/9--1(a) (West 1998)). Defendant contends that his petition sets out the gist of meritorious claims that (1) he was denied his constitutional right to be present at the jury instructions conference at which his attorneys decided not to tender an instruction on second-degree murder (720 ILCS 5/9--2(a) (West 1998)); and (2) he was denied his right to decide personally whether to tender an instruction on second-degree murder. We agree with defendant's second argument, and we reverse and remand.

7. Construction Law: Lack of written contract failed to comply with Home Repair and Remodeling Act, even though original anticipated cost was less than $1,000, and contractor could not recover on mechanics lien, and trial court  ruling denying homeowners' counterclaim for damages relating to shoddy work was error; but neither side entitled to attorney's fees. Lytton, J.

No. 3-09-0187  Roberts v. Adkins  Filed 1-7-10 (TJJ)

Plaintiff, Jerry Roberts, performed work on a home owned by defendants, Dale and Wanda Adkins (together, Adkins). When Adkins refused to pay Roberts, he recorded a mechanic’s lien on their real property. Roberts filed suit to foreclose on the mechanic’s lien. Adkins filed counterclaims and raised the Home Repair and Remodeling Act (Act) (815 ILCS 513/1 et seq. (West 2006)) as an affirmative defense. Following a bench trial, the trial court ruled in favor of Roberts and awarded him attorney fees. Adkins appeal, arguing that (1) the Act precludes Roberts from foreclosing on his mechanic’s lien, (2) Roberts is not entitled to attorney fees, and (3) they were entitled to relief on their counterclaims. We affirm in part, reverse in part, and remand.

8. Gambling Law: Affirmed: Plaintiff's multi-count complaint alleging civil conspiracy pursuant to Section 28-5 of Criminal Code against credit card companies which permitted plaintiff and others to use credit cards in connection with online gambling properly dismissed. Chapman, J.

No. 5-07-0372  Reuter v. Mastercard International, Inc.  Filed 1-5-10 (TJJ)

This appeal involves section 28-8 of the Criminal Code of 1961 (720 ILCS 5/28-8 (West 1998)). That section provides that any person who loses money or any other thing of value through illegal gambling may recover what was lost from the winner. 720 ILCS 5/28- 8(a) (West 1998). If the gambler does not bring a suit to recover his or her losses within six months of the time they occur, any other individual may bring a civil suit for damages triple the amount lost by the gambler. 720 ILCS 5/28-8(b) (West 1998). The plaintiff brought the instant lawsuit under this second provision. His complaint named as defendants MasterCard International, Inc., Visa U.S.A., Inc., and several banks that issued MasterCard and Visa credit cards to Illinois consumers who used their credit cards to gamble on Internet casinos.At issue is whether these defendants are "winners" under the statute. The trial court held that they are not and, accordingly, granted the defendants' motion to dismiss. We affirm that ruling.

9 Securities Law: Reversed and remanded: Federal Securities Litigation Uniform Standards Act of 1998 prohibited class action in Illinois state court where allegations essentially asserted negligent or willful misrepresentations of fact. Spomer, J.

No. 5-8-0260  Kircher v. Putnam Funds Trust  Filed 1-6-10 (TJJ) 

The defendants, Putnam Funds Trust, Putnam Investment Management, LLC, Evergreen International Trust, and Evergreen Investment Management Company, LLC, appeal, pursuant to Illinois Supreme Court Rule 308 (155 Ill. 2d R. 308), from a December 20, 2007, order of the circuit court of Madison County, which denied their motion for a judgment on the pleadings with respect to the class action complaint filed by Carl Kircher and Robert Brockway, individually and on behalf of all others similarly situated. The certified questions on appeal are as follows: 1. Does the Securities Litigation Uniform Standards Act of 1998 (the Securities Litigation Act) (15 U.S.C. §78bb(f)(1) (2006)) preclude this action? 2. Does the Securities Litigation Act preclude a holder of mutual funds from pursuing a putative class action in state court for the negligent management of funds? 3. Does the Securities Litigation Act preclude a holder of mutual funds from pursuing a putative class action in state court for the reckless (or willful and wanton) management of funds? 4. Does the Securities Litigation Act preclude a state law claim for a negligent failure to prevent market timing? 5. Does the Securities Litigation Act preclude a state law claim for a reckless (or willful and wanton) failure to prevent market timing? For the reasons that follow, we answer the first certified question in the affirmative, and we decline to answer the remaining certified questions. See People ex rel. Board of Trustees of Chicago State University v. Siemens Building Technologies, Inc., 387 Ill. App. 3d 606, 611 (2008) (the appellate court should refrain from answering certified questions that have no practical effect). Accordingly, we reverse the order of the circuit court that denied the defendants' motion for a judgment on the pleadings, and we remand with directions that the circuit court dismiss this action.

10. Negligence Law: Reversed and remanded: Genuine issue of material existed as to what role, if any, defendant played in sale of allegedly defective truck which, it was claimed, led to plaintiff's injuries, and trial court grant of summary judgment to that defendant was error. Wexstten, J. (Welch, J., dissenting)

No. 1-08-0409  Graham v. Bostrom Seating, Inc.  Filed 1-11-10 (TJJ)

The plaintiff, Mark Graham, appeals the Madison County circuit court's grant of a summary judgment in favor of the defendant, Cassens & Sons, Inc. (CS). The circuit court granted a summary judgment in favor of CS because it found CS was not in the chain of distribution for the sale of the vehicle-hauler truck upon which the plaintiff's claims arose and was therefore not liable under the theory of products liability.1 The plaintiff raises three points on appeal: (1) that the circuit court erred in finding that CS was not within the chain of distribution, (2) that as a matter of Illinois law, "brokers" and "facilitators" are liable for products liability claims, and (3) that even if a "facilitator" or "broker" is not liable under Illinois law, there is a genuine issue of material fact about whether CS would even so qualify. Because we find that a question of fact exists about whether CS was in the chain of distribution for the sale of the truck at issue, we do not address the remaining points.



20 Appellate Court Cases Posted 1-6-10

1.  Criminal Law: Affirmed:  Motion for continuance should be supported by offer of proof;  one good count rule about verdict forms discussed;    Coleman, J.   Theis, J., dissents
No. 1-07-0401 People v. Moore Filed 12-23-09 (LJD)  Opinion filed 6/30/09 Withdrawn

 Christopher Moore was convicted by a jury of first degree murder and armed robbery and sentenced to consecutive 30-year and 6-year terms of imprisonment as a result. In the instant appeal, he contends  that: (1) the trial court's denial of his request for a one day continuance violated his due process right to present evidence in his defense; (2) the prosecution's improper comments and misstatements of the  evidence in opening and closing argument denied him a fair trial; (3) the trial court improperly imposed a consecutive sentence on the armed robbery count on the basis of a presumption that the jury's general  verdict represented a finding that he was guilty of a more culpable homicide than felony murder; and (4) his trial counsel was ineffective in failing to tender jury verdict forms specifying the basis for the murder  verdict, thereby allowing an improper conviction of armed robbery in addition to a felony murder conviction based upon the same offense. We affirm
.

2. Criminal Law:  Affirmed: Reasonable suspicion supporting a Terry stop analyzed; minimal articulable suspicion established by officer; Plain error vs. harmless error doctrine discussed Quinn, J.

No.1-07-2826  People v. Magallanes  Filed 12-23-09 (LJD)

Following a jury trial, defendant was found guilty of burglary and sentenced, based on his criminal history, as a Class X offender (730 ILCS 5/5-5-3(c)(8) (West 2006)), to seven years in prison. On appeal,  defendant contends that: (1) the circuit court erred in failing to grant his motion to quash arrest and suppress evidence where the police officer who stopped defendant lacked a reasonable suspicion that  defendant was engaged in unlawful activity; (2) his conviction should be reversed where the circuit court failed to comply with Supreme Court Rule 431(b) (Official Reports Advance Sheet No. 8 (April 11, 2007), R. 431 (b), eff. May 1, 2007); and (3) he received ineffective assistance of counsel where trial counsel during opening remarks said it was defendant’s “side of the story” that defendant merely found  the items in the alley, but counsel failed to present defendant’s testimony or any other evidence, thereby opening the door for the State to comment during closing arguments on defendant’s lack of evidence.  or the following reasons, we affirm defendant’s conviction and sentence.

3.  Administrative Law: Affirmed: Agency decision not clearly erroneous.  Coleman, J.

No. 1-08-2859  Illinois Bell Telephone Co. v. Illinois Commerce Comm'n Filed 12-23-09 (LJD)

Illinois Bell Telephone Company appeals a decision of the Illinois Commerce Commission determining that it violated the Public Utilities Act (220 ILCS 5/13-514 (West 2006)), which provides that a  telecommunications carrier “shall not knowingly impede the development of competition in any telecommunications service market.” As a result of the determination, the Commission ordered Illinois Bell to  pay 20% of the attorney fees of the complaining parties, Sprint Communications L.P. and four affiliates (collectively, Sprint), and to pay 10% of the Commission’s costs in conducting the proceeding. We  affirm.

4.  Class Action: Certified Question: While trial judge considering class certification,defendant sought and received releases from putative class members.  If state law does not provide answer, federal statutes can be referred to for guidance. Quinn, J.

No. 1-08-2944 Lewis v. Giordano's Enterprises, Inc.  Filed 12-23-09 (LJD)

This matter is before this court on interlocutory appeal pursuant to the provisions of Illinois Supreme Court Rule 308 (155 Ill. 2d R. 308) to consider a question certified by the trial court. Defendant  Giordano’s Enterprises, Inc., which owns and operates several restaurants in the Chicago area, has a policy of automatically deducting $0.25 per hour from its hourly employees’ wages to cover the cost of  making food and beverages available to those employees while they are working.  Issue of releases from putative class members being void. Certified question answered "Yes".

Medical Negligence:Affirmed:  Dead Man's Act exception where expert for estate testifies to transaction, opposing party may testify; state of Mind exception to hearsay rule discussed.   Coleman, J.

No.  1-08-3207  Agins v. Schonberg  Filed 12-23-09 (LJD

Plaintiff, Susan Agins, the widow of Dr. Howard Agins, filed a medical negligence lawsuit against Dr. Allan Wolff, Dr. Jeffrey Schonberg, and Otolaryngology Group, Ltd., for failing to evaluate, diagnose, and  treat decedent’s malignant nasal polyp (esthesioneuroblastoma cancer), thereby contributing to his death on October 7, 2002. Following the trial, the jury returned a verdict in favor of defendants. After  hearing arguments on plaintiff’s posttrial motion for a new trial, the trial court entered judgment on the verdict. Plaintiff appeals from the denial of the posttrial motion for a new trial. We affirm.

6. Dom. Relations/Mental Health and Developmental Disabilities Confidentiality:  Affirmed: Not error for the trial court to find that petitioner had waived the patient-therapist privilege by failing to invoke it. the Trial court did not abuse its discretion by finding that Christopher failed to meet his burden of proof to show a factual basis forinjunctive relief. Coleman, J.

No. 1-08-3567   In re Marriage of Slomka   Filed 12-23-09 (RJC)

Petitioner, Christopher Slomka (Christopher), filed a motion in the circuit court of Cook County seeking a preliminary injunction to enjoin Mary Lenehan-Slomka (Mary) from taking the couple’s two minor children to therapy with psychologist Jean Gray. The circuit court denied Christopher’s motion for a preliminary injunction finding that Christopher had waived his objection to the disclosure of privileged information at the October 8, 2008, hearing by failing to assert the privilege, and that Christopher’s lack of communication with Jean Gray does not establish a factual basis for the injunctive relief Christopher requested. On appeal, Christopher argues that he did not waive privilege under the Illinois Mental Health and Developmental Disabilities Confidentiality Act (Confidentiality Act) (740 ILCS 110/1 et seq. (West 2006)), and thus it is plain error for a trial court to allow a therapist to testify in violation of the Confidentiality Act. Christopher also contends that the trial court erred by denying his motion for a preliminary injunction. We affirm.

7.  Insurance Law: Affirmed in part; reversed in part:  On appeal, plaintiff claims that the trial court erred in granting summary judgment in favor of Northland and ILM and denying his cross-motion for summary judgment. Specifically, plaintiff argues that the 11-month delay was reasonable under the circumstances because: (1) Longfellow was unsophisticated in commerce and insurance; and (2) Longfellow reasonably believed that the no claim would be made concerning the incident. App. Crt. cannot say that the 11-month delay in notifying Northland of the March 21 incident was unreasonable as a matter of law because there are factual issues that must be decided by the trial court. The judgment of the circuit court of Cook County is reversed on Northland and ILM’s motion for summary judgment and affirmed  on its denial of plaintiff’s motion for summary judgment. Gordon, Robt. E., J.

No. 1-08-1632, 1-08-1633 & 1-08-2122 Cons.   Berglind v. Paintball Business Ass'n   Filed 12-24-09 (RJC)

The sole issue in this case is whether an 11-month delay in notice of an occurrence is reasonable notice to an insurance company under the provisions of its policy. Affirmed in part; reversed in part.

8.  Administrative Hrngs./Unemployment Compensation Benefits:  Affirmed:  Claimants were not exempted under section 228 of the Act (820 ILCS 405/228 (West 2006)).  Under the circumstances of this case, we find that the paid holidays, vacation, and sick days claimants were entitled to constituted remuneration by way other than commission. The performance incentives were also properly considered by the referees. Tully, J. 

No. 1-08-1156   Western & Southern Life Insurance Co. v. Edmonson   Filed 12-24-09 (RJC)

This action arises out of the consolidation of three appeals filed by Western and Southern Life Insurance Company (Western). Each appeal was filed from circuit court judgments affirming decisions of the Board of Review (Board) of the Illinois Department of Employment Security (IDES). The decisions found that former insurances agents of Western claiming unemployment benefits, specifically Karen A. Bryan, Nikea Edmonson, and Robert Rohman (claimants), were not exempt from covered employment under the Illinois Unemployment Insurance Act (Act) (820 ILCS 405/100 et seq. (West 2006)). On appeal, Western contends that the agents were exempted under the Act and not entitled to unemployment insurance benefits. Affirmed.

9.  Medical Malpractice: Affirmed in part; cause remanded with directions:  The trial court did not abuse its discretion in permitting the evidence of financial motive to be introduced in a limited and specific manner to address the issue of the defendants' compliance with the standard of care.  The trial court properly determined that a new trial was not justified because the jury's conclusion was not against the manifest weight of the evidence. The trial court did not abuse its discretion in denying the defendants' motion for a new trial.  Nothing to suggest the jury's award of $100,000 to cover these additional charges resulted from passion or prejudice, or that it exceeded the necessarily flexible limits of fair and reasonable compensation. Accordingly, it was an abuse of discretion for the trial court to subject the jury's award to remittitur for $100,000. Hall, J. with Garcia, J. dissenting.  

No. 1-08-0265   Martinez v. Elias   Filed 12-28-09 (RJC)

The plaintiff, Thomas Martinez, filed a medical malpractice case against the defendants, Samuel Elias, M.D. and the Bone & Joint Center, alleging that Dr. Elias performed unnecessary procedures on the plaintiff's lower spine. Following trial, the jury returned a verdict in favor of the plaintiff and against the defendants in the amount of $500,000. The trial court granted the defendants' posttrial motion for a remittitur and reduced the jury award to $400,000. The defendants appeal raising the following issues: whether the admission of a financial motive for the surgery was error and whether a new trial is required because the verdict was against the manifest weight of the evidence. The plaintiff crossappeals, challenging the granting of the remittitur. Affirmed in part; cause remanded with directions.

10.  Insurance Law/Summary Judgment: Affirmed:  Plaintiff contends the patrol car in which he was injured was not a vehicle furnished or available for his regular use within the meaning of the regular use exclusion of his State Farm automobile policy. The trial court correctly held that the patrol car occupied by plaintiff at the time of the accident was furnished or available for his regular use, within the meaning of his policy’s uninsured motorist coverage exclusion. The trial court’s order granting summary judgment for State Farm and denying summary for plaintiff is affirmed.  Lampkin, J.     

No. 1-09-0553   Ryan v. State Farm Mutual Automobile Insurance Co.   Filed 12-28-09 (RJC)

In this dispute involving a vehicle collision and uninsured motorist coverage, the insured, plaintiff Gerald Ryan, appeals the trial court’s grant of summary judgment in favor of his insurer, defendant State Farm Mutual Automobile Insurance Company (State Farm). Plaintiff contends he is entitled to coverage because the vehicle at issue was not furnished or available for his regular use and, thus, not excluded from uninsured motorist coverage under his State Farm insurance policy. For the reasons that follow, we affirm the judgment of the trial court.

11.  Criminal Law: Affirmed:   It was reasonable for the trial court to find that Taylor believed death was imminent, and the mere fact that he asked police officer if he was going to die did not negate such belief. It is unlikely that a person who did not believe he was dying would pose such a question to anyone.  Although victim Taylor was seriously wounded, we find that the trial court could find beyond a reasonable doubt that victim possessed sufficient mental faculties to give accurate statements to police officer about the circumstances.  Additionally, the admission of  victim's dying declaration did not violate the defendant’s rights to confrontation under the sixth amendment. The cross-examination requirement under section 115-10.1 was met and the trial court did not abuse its discretion in admitting the prior inconsistent statement as substantive evidence. Cunningham, J.          

No. 1-07-1769   People v. Hatchett   Filed 12-29-09 (RJC)

Following a bench trial in the circuit court of Cook County, defendant Derrick Hatchett was convicted of first-degree murder and sentenced to 45 years of imprisonment. On appeal, the defendant argues that: (1) he was denied a fair trial when the trial court admitted the decedent’s statement as an excited utterance and/or dying declaration; (2) he was denied a fair trial when the trial court permitted the handwritten statement of a testifying witness, Tron Johnson, to be introduced as substantive evidence; (3) he was denied a fair trial when the trial court refused the defense counsel’s requests to recall Tron Johnson and for a one-day continuance to secure witnesses;  (4) the defendant was denied effective assistance of counsel; and (5) the defendant’s guilt was not proven beyond a reasonable doubt. For the following reasons, we affirm.

12.  Property/Tax Deeds: Reversed and remanded:   The application of sections 22-45(4) and 2-1401(f) is an issue of first impression in this court.  Where, as here, numerous errors in the process of determining the identity of the record owner of the property result in a total lack of notice to the record owner, the record owner is entitled to relief from the tax deed under section 22-45(4).  Total lack of notice means that the circuit court never acquired personal jurisdiction over Devon, even though this action could be described as in rem or quasi-in rem. This, in turn, means that the tax deed was void.  We find that Miller did not prove that he was a bona fide purchaser for value.  Because we find Miller was not a bona fide purchaser, he is
not entitled to protection of his interest over that of Devon.  For these reasons, we reverse the judgment of the circuit court, and remand this cause with directions for the circuit court to set aside the tax deed under section 2-1401(f) of the Code of Civil Procedure and section 22-45(4) of the Property Tax Code. Theis, J.            

No. 1-08-1737   In re Application of the County Collector   Filed 12-29-09 (RJC)

Petitioner, Devon Bank, appeals from the order of the circuit court of Cook County denying its motion for summary judgment and granting the cross-motion for summary judgment filed by respondent, Bruce Miller. Devon had filed a petition pursuant to section 2-1401 of the Code of Civil Procedure (735 ILCS 5/2-1401 (West 2006)) seeking to set aside a tax deed issued to respondent Checkmate Acquisitions, Inc., regarding certain property to which Devon held legal title, contending that it had never received any notice of the sale, as required by the Property Tax Code (35 ILCS 200/1-1 et seq. (West 2006)). Miller had responded that he was a bona fide subsequent purchaser of the property for value and that because a lack of jurisdiction did not affirmatively appear on the face of the tax deed proceeding record, under section 2-1401(e) of the Code of Civil Procedure (735 ILCS 5/2-1401(e) (West 2006)), he had a superior right to the property. The circuit court agreed with Miller.

13.  Workers' Compensation: Affirmed: The Commission's findings that claimant failed to prove by a preponderance of the credible evidence that he sustained accidental injuries arising out of or in the course of his employment with claimant on June 4, 2004, or August 2, 2004, are not contrary to the manifest weight of the evidence. Hudson, J.             

No. 1-08-13238WC   Hosteny v. Illinois Workers' Compensation Comm'n   Filed 12-29-09 (RJC)

Claimant, Jerry Hosteny, filed three applications for adjustment of claim pursuant to the Workers' Compensation Act (Act) (820 ILCS 305/1 et seq. (West 2004)) for injuries he allegedly sustained while in the employ of respondent, Anning Johnson Co. Following a hearing, the arbitrator determined that claimant sustained compensable accidents on two of the three alleged accident dates. The arbitrator awarded claimant medical expenses, temporary total disability (TTD) benefits, and permanent partial disability (PPD) benefits. Respondent appealed, and the Illinois Workers' Compensation Commission (Commission) reversed. On judicial review, the circuit court of Cook  County confirmed. Before this court, claimant challenges the Commission's findings that he failed to sustain his burden of proving compensable injuries arising out of and in the course of his employment on June 4, 2004, and August 2, 2004. For the reasons that follow, we affirm.

14. Aviation Law: Affirmed in part, reversed in part, dismissed in part: In action relating to airplane crash which killed two persons in 2001 in a plane manufactured in 1969, trial court erred in granting summary judgment on negligence and implied warranty counts, but summary judgment on counts against some defendants upheld pursuant to statute of repose in federal General Aviation revitalization Act; also, state Illinois Distributor Statute was not complied with as to one defendant, and appellate court had no jurisdiction with respect to that defendant. Karnezis, J.

No. 1-09-0148  Southside Trust & Savings Bank v. Mitsubishi Heavy Industries, Ltd  Filed 12-29-09 (TJJ)

Plaintiff, Southside Trust and Savings Bank of Peoria, is the personal representative of the estates of Christine Marie White (Christine) and John Michael White (Michael). Christine and John were killed when the small plane owned and piloted by Michael crashed in New Mexico. Plaintiff filed an action in the Circuit Court of Cook County asserting product liability and negligence claims against the manufacturers and sellers of the plane and its component parts, Mitsubishi Heavy Industries, Ltd. (Mitsubishi), Mitsubishi Heavy Industries America, Inc. (Mitsubishi America), Honeywell International, Inc. (Honeywell), Woodward Governor Company (Woodward) and Air 1st Aviation Companies (Air 1st) (collectively defendants), and breach of warranty claims against Air 1st.1 The court dismissed plaintiff’s product liability claims against Air 1st and granted summary judgment to defendants on all remaining claims. On appeal, plaintiff argues the court erred in dismissing plaintiff’s claims and/or granting summary judgment to defendants. It asserts the court erred in (1) misapplying section 2-621 of the Illinois Code of Civil Procedure (735 ILCS 5/2-621 (West 2006))2, Federal Aviation Administration Regulation 91.403(a) (14 C.F.R. §91.403(a)) and the facts to plaintiff’s claims against Air 1st and (2) finding the 18-year statute of repose provided by the General Aviation Revitalization Act of 1994 (49 U.S.C. § 40101, Note (2000)) (GARA) applicable to its claims against the other defendants. We affirm in part, reverse in part and dismiss in part.

15. Criminal Law: Reversed and remanded: In insanity case, where experts for both prosecution and defense both agree that at time of offense defendant was suffering from a "hyper-religious" delusion, trial court finding of guilty but mentally ill was erroneous, and matter remanded for proceedings in connection with finding of not guilty by reason of insanity. Gordon, J., J. (McBride, J., dissenting)

No. 1-08-0657  People v. Kando  Filed 12-30-09 (TJJ)

Defendant, Amir Kando, was arrested and charged with aggravated battery and attempt murder of his neighbor, Jason Burley. At his bench trial, defendant raised the insanity defense pursuant to section 6-2 of the Criminal Code of 1961 (Code) (720 ILCS 5/6-2 (West 2002)). The trial court found defendant guilty but mentally ill and subsequently sentenced him to 15 years’ imprisonment. On appeal, defendant makes several contentions. He first argues that his conviction should be reversed because the trial court’s finding of guilty but mentally ill was against the manifest weight of the evidence. In the alternative, defendant contends that his cause should be remanded for a new trial because he was denied his right to due process when the trial court failed to correctly recall and consider testimony by several witnesses, whose testimony was crucial to defendant’s insanity defense, and where it instead relied on matters that were not part of the record. Defendant also asserts that he was denied his constitutional right to effective assistance of counsel, where counsel: (1) failed to properly handle his insanity defense by failing to impeach two of the State’s key witnesses, and (2) failed to object to a discovery violation by the State. Defendant finally contends that even if his conviction is affirmed, we should nevertheless remand for a new sentencing hearing because the trial court abused its discretion when it sentenced him to 15 years’ imprisonment, a sentence nine years above the statutory minimum.1 For the reasons set forth below, we reverse.

16. Criminal Law: Affirmed: Trial court failure to read to jury instruction regarding defendant's failure to testify not plain error in light of proper written instruction and overwhelming evidence of guilt, out-of-court statement not hearsay, and 50-year sentence for first degree murder not excessive. Lampkin, J.

No. 1-07-2506  People v. Nugen  Filed 12-31-09 (TJJ)

A jury found defendant Wardell Nugen guilty of first degree murder. He was sentenced to 50 years’ imprisonment. On appeal, defendant contends he was denied his right to a fair trial where the jury was not read Illinois Pattern Jury Instructions, Criminal, No. 2.04 (4th ed. 2000) (hereinafter IPI Criminal 4th No. 2.04), pertaining to his constitutional right not to testify. Defendant also contends the admission of an out-of-court statement violated the sixth amendment confrontation clause. Defendant further contends his sentence is excessive in light of mitigating factors. We affirm.

17. Criminal Law: Affirmed in part, vacated in part, and remanded: Three separate convictions for aggravated battery violated "one act, one crime" rule, and extended term sentence not proper where more than 10 years passed from date of defendant's prior qualifying conviction and sentencing, even though passage of time stemmed from defendant's failure to appear in court during pendency of case for over six years. Lampkin, J.

No. 1-08-1090  People v. Garcia  Filed 12-31-09 (TJJ)

Following a bench trial, defendant Abraham Garcia was found guilty of three counts of aggravated battery and was sentenced to three extended 90-month prison terms, to be served concurrently. On appeal, defendant asserts his three convictions violate the one-act, one-crime doctrine and his extended-term sentences are void.

18. Zoning Law: Affirmed in part, reversed in part and remanded: Municipal zoning ordinance did not violate plaintiff church's right to free exercise of religion or discriminate against churches, nor did it violate Illinois Religious Freedom Restoration Act, but cause remanded to determine whether denial of special use permit complied with due process in light of subsequent amendment of ordinance. Schostok, J.

No. 2-08-0105  Our Savior Evangelical Lutheran Church v. Saville  Filed 12-31-09 (TJJ)

The plaintiff, Our Savior Evangelical Lutheran Church (Our Savior or the church), applied for (1) a site plan review of its proposed new building addition, parking lot, and driveway, or, in the alternative, (2) a special use permit for the same improvements to the church's property. After the defendants, Michael B. Saville, Mayor pro tem; the City Council of the City of Aurora; the City of Aurora; Margaret Truax, Chairman of the Aurora Zoning Board of Appeals; and the Aurora Zoning Board of Appeals (collectively, the city), denied the applications, the church filed suit, claiming that the denials of its applications were contrary to the manifest weight of the evidence and denied the church due process. The trial court entered judgment for the city, and the church appealed. We affirm in part, reverse in part, and remand.

19. Criminal Law: Affirmed: Public school is "public property" for purposes of aggravated battery statute, despite fact that access is usually restricted to students and staff, and not granted to general public. Bowman, J.

No. 2-08-0155  People v. Ojeda  Filed 12-31-09 (TJJ)

At issue in this appeal is whether a high school that is funded by taxes collected from local property owners is considered "public property" for purposes of the aggravated battery statute (see 720 ILCS 5/12--4(b)(8) (West 2006)). For the reasons that follow, we determine that a public high school is "public property," and, thus, we affirm.

20. Negligence Law: Reversed and remanded: "Contact sports" exception did not apply to negligence action alleging that defendant shot hockey pucks at water bottles in area where plaintiff would go to re-fill bottles pursuant to his job duties, and dismissal of those counts pursuant to Section 2-619 of Code of Civil procedure was error.  Hutchinson, J.

No. 2-08-0789  Weisberg v. Chicago Steel  Filed 12-31-09 (TJJ)

Pursuant to Supreme Court Rule 304(a) (210 Ill. 2d R. 304(a)), plaintiff, Michael Weisberg, appeals an order from the trial court granting the motion of defendants, Chicago Steel and Cody Lampl, to dismiss pursuant to section 2--619 of the Code of Civil Procedure (the Code) (735 ILCS 5/2--619 (West 2004)); the order dismissed counts I and II of plaintiff's four-count amended complaint. Counts I and II alleged negligence against defendants, and counts III and IV alleged willful and wanton conduct against defendants, respectively. The only issue raised on appeal is whether the trial court erred when it granted defendants' motion to dismiss with respect to counts I and II. For the reasons set forth below, we reverse and remand.

7 Appellate Court Cases Posted 1-5-10

1. Tort Immunity: Affirmed: Affidavit in support of motion for summary judgment complied with Supreme Court Rule 191, and nature of gravel lot maintained by defendant municipality, and "historical use" of it, were such that summary judgment in favor of defendant in face of claim for personal injury suffered in fall was proper pursuant to Tort Immunity Act. O'Malley, J.

No. 2-08-0821  Doria v. The Village of Downers Grove  Filed 12-29-09 (TJJ)

Plaintiff, Richard Doria, appeals the circuit court's order granting summary judgment in favor of defendant, the Village of Downers Grove, on plaintiff's complaint seeking to hold defendant liable for the allegedly defective condition of the convergence of a gravel area and roadway on which plaintiff fell. On appeal, plaintiff argues that the trial court allowed defendant to introduce a defective affidavit into evidence and that the trial court erred in concluding that defendant was not liable pursuant to section 3--102(a) of the Local Governmental and Governmental Employees Tort Immunity Act (Act) (745 ILCS 10/3--102(a) (West 2006)). For the reasons that follow, we affirm.

2. Criminal Law: Reversed and remanded: Trial court ruling finding defendant guilty upon ruling on defendant's motion for "directed finding," without inquiring as to whether defendant wished to present evidence, plain error requiring a new trial. Wright, J. (Schmidt and Holdridge, JJ., filed separate concurring opinions).

No. 3-08-0618  People v. Faint  Filed 12-18-09 (TJJ)

After the State concluded its portion of the evidence during a bench trial, the defense moved for a directed verdict. After hearing arguments on the motion, the judge did not make a ruling on the motion but instead pronounced defendant guilty of driving under the influence and then immediately sentenced defendant to a term of supervision. Defense counsel did not object to the trial court’s finding of guilt but later raised the trial court’s failure to allow defendant an opportunity to present evidence in a posttrial motion. The trial court denied defendant’s motion for a new trial. Defendant filed a timely notice of appeal. We reverse and remand for trial.

3. Civil Procedure: Reversed and remanded: Trial court dismissal  of plaintiff's action for lack of diligence in serving defendant in personal injury action deemed an abuse of discretion in light of relatively short time from date of filing and service, and plaintiff's efforts to locate defendant. Carter, J. (Schmidt, dissenting).

No. 3-08-0930  Verploegh v. Gagliano  Filed 12-18-09 (TJJ)

The plaintiff, Sharon Verploegh, filed a complaint against the defendant, Mark Gagliano, on August 15, 2007, for damages allegedly arising out of an automobile accident on August 23, 2005. The defendant was served on March 17, 2008, and thereafter filed a motion to dismiss the complaint pursuant to Supreme Court Rule 103(b). Official Reports Advance Sheet No. 14 (July 4, 2007), R. 103(b), eff. July 4, 2007. The trial court granted the motion and dismissed the complaint with prejudice. The plaintiff appeals, claiming the court abused its discretion when it granted the defendant’s motion. We reverse the trial court’s judgment and remand for further proceedings.

4. Child/Parent Law: Affirmed: Trial court finding that respondent mother was an unfit parent and unable to care for child not against manifest weight of evidence, and trial court could properly consider prior determinations of unfitness relating to respondent and other children. Carter, J.

No. 3-08-0934  In re J.C., Jr., a Minor  Filed 12-29-09 (TJJ)

The respondent, T.C., is the biological mother of the minor J.C. She appeals from the trial court’s dispositional order under the Juvenile Court Act (the Act) and challenges the decisions of the trial court that J.C. was neglected and that T.C. was unfit. 705 ILCS 405/1–1 et seq. (West 2008). After a review of the parties’ arguments and the record, we affirm.  

5. Insurance Coverage: Affirmed: Trial court properly granted summary judgment to insurance company in declaratory judgment action that insurance company was not obligated under homeowners' policy to indemnify or defend lawsuit stemming from death of minor decedent who had allegedly been supplied with alcohol by a person or persons in defendants' household. Holdridge, J.

No. 3-08-0654  Allstate Insurance Company v. Greer  Filed 12-30-09 (TJJ)

Allstate Insurance Company (Allstate) filed a declaratory action seeking a judgment declaring that the company was relieved from providing insurance coverage for Matthew Leifheit, David Leifheit, and Karen Leifheit (the Leifheits) in a lawsuit filed against them by Carol Greer and Michael Mielczarek (the decedent's parents). Allstate later filed a motion for summary judgment, which was granted. The decedent's parents filed the instant appeal from the order granting summary judgment. We affirm.

6. Child/Parent Law: Affirmed: Fact that respondent father was himself a minor did not prohibit proceedings to terminate parental rights, Adoption Act did not proscribe or limit proceedings, and trial court's decision to terminate parental rights not against manifest weight of the evidence. Holdridge, J. (McDade, J., specially concurring).

No. 3-09-0547  In re I.B., a Minor  Filed 12-30-09 (TJJ)

The trial court found the respondent father, M.L., unfit to care for the minor, I.B., and that it was in the best interest of the minor that the respondent's parental rights be terminated. The respondent appeals, arguing that: (1) the trial court was prohibited from finding him unfit because he was a minor, age 15 years old; (2) he was denied his right to procedural due process because the State sought to find him unfit under section 1(D)(e) of the Adoption Act (Act) (750 ILCS 50/1(D)(e) (West 2008)), and he was not allowed the opportunity to correct the conditions that led to the removal of the minor; and (3) the trial court's best interest determination was against the manifest weight of the evidence. We affirm.

7. Medical Insurance Coverage Law: Affirmed: Medical malpractice insurer not obligated to defend or indemnify insured doctor in qui tam suit by former employees relating to fraudulent Medicare billing, beyond provision in policy for payments in connection with "Medicare investigation." Chapman, J.

No. 5-08-0426  Ismie Mutual Insurance Company v. Michaelis Jackson & Associates  Filed 12-30-09 (TJJ)

In this declaratory judgment action, defendants Michaelis Jackson & Associates, LLC, and Michaelis Billy Jackson, M.D. (collectively Jackson), appeal from the trial court's July 16, 2008, order granting the motions filed by ISMIE Mutual Insurance Company (ISMIE) for a judgment on the pleadings and for a summary judgment from the trial court's order of the same date denying Jackson's motion for a summary judgment. At issue was ISMIE's duty to defend and indemnify Jackson for a suit brought by Marsha Turner and Carolyn Swartos, former employees of Jackson. These former employees had filed a qui tam suit against Jackson and alleged that Jackson had performed numerous medically unnecessary cataract surgeries and invasive follow-up procedures. ISMIE took the position that the allegations of the former employees fell outside of ISMIE's policy coverage. Specifically, ISMIE argued that there were no claims alleged against Jackson involving "personal injury" caused by "professional services." We affirm.