In re Jonathon C.B.
2011 IL 107750
| Ill. | 2011Background
- Jonathon C.B., 16 at the time, was adjudicated delinquent for criminal sexual assault and attempted robbery and committed to IDJJ for an indeterminate term terminating at age 21 or in 15 years.
- The case arose from CH’s July 10–11, 2006, assault and robbery in Champaign County, with trial evidence including CH’s testimony and corroborating police and medical witnesses.
- The defense argued insufficient proof of criminal sexual assault beyond a reasonable doubt and highlighted inconsistencies in CH’s statements and police/investigator testimony.
- The trial occurred with Jonathon shackled; no Boose-type hearing was conducted to determine necessity of restraints, and the record provides no clear indication the judge was aware of shackling at the outset.
- The appellate court affirmed the delinquency adjudication; issues included sufficiency of evidence, shackling error, and the statute denying a jury trial to minors in most delinquency proceedings.
- The Illinois Supreme Court affirmed the appellate court, holding the evidence sufficient and declining to find reversible Boose-shackling error based on the record, while addressing the jury-trial issue under long-standing juvenile law precedent.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether evidence proves CSA beyond a reasonable doubt | C.B. argues CH’s credibility issues undermine proof | State contends cumulative testimony and physical evidence establish the offense | Sufficient evidence; rational trier could find guilt beyond reasonable doubt |
| Whether shackling without a Boose hearing violated due process | Jonathon contends Boose hearing required; shackling prejudicial | State asserts no plain error given lack of record of awareness and no objections | No reversible error; no affirmative record showing trial court knew of shackling before testimony |
| Whether §5-101(3) of the Juvenile Court Act denying a jury trial for most delinquency cases violates rights | Jonathon asserts lack of jury trial violates due process and equal protection | State maintains long-standing usurpation of jury rights in juvenile proceedings remains valid | Statute constitutional; juvenile proceedings not criminal prosecutions for purposes of jury trial right |
Key Cases Cited
- People v. Boose, 66 Ill. 2d 261 (1977) (shackling admonitions; need for manifest necessity and Boose hearing)
- In re Staley, 67 Ill. 2d 33 (1977) (parens patriae rationale; shackling in absence of manifest necessity)
- People v. Allen, 222 Ill. 2d 340 (2006) (Boose framework; necessity to justify restraints even when defendant unobjected)
- McKeiver v. Pennsylvania, 403 U.S. 528 (1971) (jury trial not required in juvenile adjudicative proceedings; fundamental fairness concerns)
- In re Lakisha M., 227 Ill. 2d 259 (2008) (delinquency not criminal conviction; privacy considerations and DNA testing)
- People ex rel. Devine v. Stralka, 226 Ill. 2d 445 (2007) (parens patriae and protection of minors; advancement of juvenile protections)