The case involved Walter Edwards, who was convicted by a jury of first-degree murder under a theory of accountability for the 1998 shooting death of Jacqueline Bernaugh and sentenced to 28 years in prison. Edwards filed multiple successive petitions for post-conviction relief under the Post-Conviction Hearing Act, claiming actual innocence based on newly discovered evidence in the form of affidavits from codefendants stating he was not involved in the crime. The circuit court denied him leave to file his third and fourth petitions, and the appellate court affirmed. The Illinois Supreme Court affirmed those decisions, holding that even assuming the affidavits constituted new evidence, they failed to raise the probability that no reasonable juror would have convicted him in light of the new evidence, particularly given his conviction under accountability and his own prior statement placing him at the scene.
The case concerned whether Whitney Wisnasky-Bettorf could appear on the November 2010 general election ballot as the Republican nominee for St. Clair County board of review after the party committee appointed her to fill a vacancy created when no candidates were listed on the primary ballot and none were nominated as write-ins. The county electoral board and lower courts sustained an objection and removed her name, ruling that the committee had not timely filed a resolution under section 7-61 of the Election Code. The Illinois Supreme Court reversed, holding that paragraph 9 of the statute sets forth a distinct procedure for such vacancies that requires only a notice of appointment and nominating petitions rather than the resolution referenced in paragraph 3, and that the candidate had complied with those requirements.
The case concerned whether Illinois School Code sections 34-18(31) and 34-84 grant laid-off tenured Chicago public school teachers a right to be rehired after economic layoffs or specific procedures in the rehiring process. The Supreme Court of Illinois, answering certified questions from the Seventh Circuit, held that the statutes confer no such rights. The court reasoned that the provisions give the Board sole authority over teacher employment, layoffs, and discharges without any language creating recall entitlements, preferences for tenured teachers, or mandated rehiring processes, distinguishing this from other statutory schemes that do provide such rights.
In this case, defendant Marina Kladis was charged with DUI after a traffic stop and requested production of the arresting officer's squad-car video recording through a Rule 237 notice and a Schmidt discovery motion filed before the first court date. The State failed to obtain or preserve the recording, which was automatically purged by police policy hours before the initial hearing, prompting the trial court to impose a discovery sanction barring the State from introducing any testimony about the video's contents. The Illinois Supreme Court affirmed, holding that the State had clear notice of the request yet took no steps to prevent destruction, and that the tailored sanction was a proper exercise of discretion that did not prevent the State from presenting other evidence at trial. The matter was remanded for further proceedings on the DUI charge.
In People v. Johnson, the Illinois Supreme Court considered whether defendant Amos Johnson, convicted of possession of a controlled substance after 344 days of presentence incarceration, could apply his statutory $5-per-day credit under section 110-14 of the Code of Criminal Procedure to offset a $200 DNA analysis charge imposed under section 5-4-3(j) of the Unified Code of Corrections. The court affirmed the appellate court's ruling that the charge was not subject to offset. The core reasoning was that the DNA charge functions as a compensatory fee to cover the costs of sample analysis, genetic database maintenance, and related laboratory operations rather than a punitive fine, as shown by the statute's text directing the funds to a special State Offender DNA Identification System Fund for non-punitive purposes and by comparison to similar statutes in other states.
The case involved Reliable Fire Equipment Company suing former employees Arnold Arredondo and Rene Garcia, along with their new company High Rise Security Systems, for allegedly breaching noncompetition restrictive covenants in their employment agreements by starting a competing business and soliciting customers and employees. The circuit court and appellate court ruled the covenants unenforceable, finding that Reliable failed to establish a legitimate business interest justifying enforcement under the prevailing test. The Illinois Supreme Court reversed these decisions, holding that the validity of such covenants must be assessed based on the totality of the circumstances rather than a rigid legitimate business interest requirement, and remanded the case for further proceedings applying the correct standard.
