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