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People v. Richardson
2015 IL 118255
Ill.
2015
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Background

  • In March 2012 Jermaine Richardson (then 17) allegedly committed sexual offenses; he was indicted in June 2013 as an adult.
  • At the time of the alleged offenses, the Juvenile Court Act’s exclusive jurisdiction applied to minors under 17.
  • Public Act 98-61 (effective Jan. 1, 2014) amended the Act to include 17-year-olds but included a saving clause limiting application to offenses committed on or after the effective date.
  • Richardson moved to declare adult prosecution unconstitutional, arguing the saving clause violated his equal protection rights by treating similarly situated 17-year-olds differently.
  • The Du Page County circuit court agreed, held the saving clause unconstitutional as applied to Richardson, and transferred the case to juvenile court. The State appealed directly to the Illinois Supreme Court.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether the saving clause in the Juvenile Court Act amendment violates equal protection The State: the saving clause is a rational legislative choice advancing legitimate interests (administrative clarity, finality, resource preservation) Richardson: the clause irrationally excludes those who committed offenses before the effective date despite identical status as 17-year-olds Court: Saving clause is rationally related to legitimate state interests; no equal protection violation; circuit court reversed

Key Cases Cited

  • People v. Grant, 71 Ill. 2d 551 (1978) (upholding temporal savings distinctions to avoid reopening completed proceedings)
  • Braeburn Securities Corp. v. Smith, 15 Ill. 2d 55 (1958) (Fourteenth Amendment does not forbid statutes and statutory changes from having a beginning)
  • Sperry & Hutchinson Co. v. Rhodes, 220 U.S. 502 (1911) (statutory changes may distinguish rights at earlier and later times)
  • In re Derrico G., 2014 IL 114463 (statute presumed constitutional; challenger bears burden)
  • People v. Watson, 118 Ill. 2d 62 (1987) (legislative classifications must have fair and substantial relation to legislative objective)
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Case Details

Case Name: People v. Richardson
Court Name: Illinois Supreme Court
Date Published: Jun 26, 2015
Citation: 2015 IL 118255
Docket Number: 118255
Court Abbreviation: Ill.