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People v. Veronica C.
239 Ill. 2d 134
| Ill. | 2010
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Background

  • Respondent Veronica C. was adjudicated delinquent for battery (12-3(a)(2)) in Kane County; placed on one year of probation with conditions and fees.
  • The State charged two counts: battery causing bodily harm and insult/provoking contact; only the second count went to trial.
  • Trial court found respondent guilty of battery (insult/provoking contact) but not bodily harm; the court criticized respondent’s credibility.
  • At sentencing, court placed respondent on probation for one year despite defense immigration? (note: the record shows probation was imposed); State objected to supervision.
  • Respondent appealed, arguing 5-615 of the Juvenile Court Act unlawfully restricts supervision by prohibiting it without State consent; appellate court rejected, and the Supreme Court granted leave to appeal.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether respondent has standing to challenge 5-615(1) Respondent lacks standing; she was not adversely affected by the objection. State contends respondent was not prejudiced after guilt finding; standing not met. Respondent lacked standing; court did not address merits.
Constitutionality of 5-615(1) under equal protection Appellant asserts disparate treatment for juveniles versus adults. Appellee argues juveniles are treated differently to promote rehabilitation. Court did not reach merits; affirmed without addressing standing, and upheld result on other grounds.
Whether mootness bars review of probation-eligibility issue N/A (not independently framed as a live issue). N/A Not reached; court affirmed on basis of standing and result.

Key Cases Cited

  • In re Samantha V., 234 Ill.2d 359 (2009) (distinguishes findings, adjudication, and dispositional phases; admissibility of evidence in delinquency findings)
  • In re Stralka, 226 Ill.2d 445 (2007) (prohibition on vacating delinquency by court if it would bypass State’s right to reject supervision)
  • In re T.W., 101 Ill.2d 438 (1984) (separation-of-powers concern regarding identical predecessor statute to 5-615(1))
  • In re J.N., 91 Ill.2d 122 (1982) (probation/conditional-discharge vs supervision; limits on continuing under supervision after findings)
  • People v. Presley, 47 Ill.2d 50 (1970) (juvenile versus adult treatment; purpose of distinct juvenile proceedings)
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Case Details

Case Name: People v. Veronica C.
Court Name: Illinois Supreme Court
Date Published: Nov 22, 2010
Citation: 239 Ill. 2d 134
Docket Number: 108953
Court Abbreviation: Ill.