People v. Jackson
2011 IL 110615
| Ill. | 2011Background
- Jackson and Lee were convicted of possessing less than 15 grams of a controlled substance and were each ordered to pay a $10 Arrestee’s Medical Costs Fund assessment under 730 ILCS 125/17.
- The statute was amended in August 2008; the amendment (Pub. Act 95-842) changed who and how the fund could be used, and when the fee is collected.
- Jackson challenged the preamended version arguing the statute limited the fee to arrestees for whom the county incurred medical expenses and that he received no medical treatment.
- Lee challenged the imposition arguing he did not require or receive medical services, though his case relied on the amended provision; the appellate court upheld the assessment in both cases.
- The State contends the fund operates as health insurance for all arrestees and funds medical costs for arrestees regardless of whether they personally incurred expenses in custody.
- The Supreme Court affirmed Jackson’s judgment, dismissed Lee’s appeal as improvidently granted, and addressed whether preamended or amended section 17 applies and the legislative intent behind the fund.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Authority to impose without treatment | Jackson | Jackson | Pre-amendment section 17 authorizes the $10 fee regardless of treatment. |
| Amendment applicability and ex post facto | State | Jackson | Amendment clarifies and applies; no ex post facto issue governs the result. |
| Lee’s appeal viability | State/Lee | Lee | Lee’s appeal improvidently granted; dismissed. |
| Fund interpretation | State | Jackson | Fund is for all arrestees and allows administration of the fund, not limited to those who incurred injuries. |
Key Cases Cited
- People v. Cleveland, 393 Ill. App. 3d 700 (2009) (pre-amendment interpretation rejected for not requiring injury-based costs)
- Coleman, 404 Ill. App. 3d 750 (2010) (rejects injury-based limitation under preamended section 17)
- Hubbard, 404 Ill. App. 3d 100 (2010) (confirms broader reading of the statute)
- Jones, 397 Ill. App. 3d 651 (2009) (supports general fund use beyond individual injuries)
- Unander, 404 Ill. App. 3d 884 (2010) (statutory language not limited to arrestees incurring injuries)
- Evangelista, 393 Ill. App. 3d 395 (2009) (distinguishes collection from use of fund)
- O’Donnell, 116 Ill. 2d 517 (1987) (statutory interpretation framework for legislative intent)
- People v. Garcia, 241 Ill. 2d 416 (2011) (general principles of statutory interpretation and intent)