In re Shelby R., 2013 IL 114994

Respondent Shelby R., age 14, was the subject of a petition for adjudication of wardship in Champaign County in December 2009 for domestic battery, aggravated assault, and unlawful consumption of alcohol.
Respondent entered a denial; charges included waving a knife at a family member and tearing clothing, with a breath test showing 0.142 BAC.
Respondent entered a residential substance abuse treatment program but left before completion in April 2010; she later pled guilty to unlawful consumption of alcohol in June 2010 and was adjudicated a delinquent minor and ward of the court.
The court sentenced Respondent to 18 months’ probation in July 2010, with conditions including abstaining from alcohol and random drug testing.
In September 2010, the State petitioned to revoke probation; Respondent admitted the violation; the court revoked probation and sentenced her to an indeterminate term of 364 days in the Department of Juvenile Justice (DJJ).
The appellate court reversed the trial court’s DJJ commitment, holding the Juvenile Court Act does not authorize incarceration of a minor for unlawful consumption of alcohol; the State sought review in the Illinois Supreme Court.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Juvenile Court Act authorizes DJJ commitment for unlawful alcohol consumption.	People argued the Act permits any sentence available under 5-710 upon probation revocation.	Shelby argued incarceration for unlawful consumption is barred by 5-710, 5-720, and 1-4.1 limitations.	No authority to commit; statute does not authorize DJJ imprisonment for unlawful consumption.
Does section 1-4.1 authorize incarceration for violating a court order after adjudication?	People contend 1-4.1 permits incarceration for violations of a court order.	Shelby contends 1-4.1 applies before adjudication and cannot override post-adjudication sentencing.	1-4.1 does not authorize post-adjudication incarceration for the offense found; inapplicable here.
Was the public-interest mootness exception appropriate to review the moot sentencing issue?	People maintain the issue is of public importance and merits review despite mootness.	Shelby contends no public-interest need given lack of conflict in precedent.	Yes; public-interest exception applied; merits review of the sentencing issue.

In re Wallace v. Labrenz, 411 Ill. 618 (1952) (public-interest exception origin for moot questions)
People v. Roberson, 212 Ill. 2d 430 (2004) (mootness and review of moot sentences allowed in certain circumstances)
In re D.F., 208 Ill. 2d 223 (2003) (statutory construction and plain-meaning approach)
In re C.C., 2011 IL 111795 (2011) (statutory interpretation of juvenile statutes)
Labrenz, 411 Ill. 618 (1952) (public interest exception rationale and application)
Sandholm v. Kuecker, 2012 IL 111443 (2012) (attorney fees; public-interest review guidance)