People v. Villa, 355 Ill. Dec. 220

Villa was convicted by a Boone County jury of aggravated battery with a firearm and aggravated discharge of a firearm under an accountability theory, receiving concurrent sentences of 14 years and 5 years.
Prior to trial, Villa had a August 2006 juvenile burglary adjudication, less than a year before the current offenses.
The State sought to use the juvenile adjudication for impeachment if Villa testified, and the trial court admitted it after balancing under Montgomery.
The juvenile adjudication was introduced during rebuttal and referenced in closing arguments by the State to challenge Villa's trial credibility.
Appellate Court affirmed; the Supreme Court granted propensity for review to resolve the statutory-constitutional question about admissibility of juvenile adjudications against a testifying defendant.
The dispute centers on section 5-150(1)(c) of the Juvenile Court Act and its relation to the Montgomery rule governing admissibility of juvenile adjudications.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether 5-150(1)(c) permits impeachment with juvenile adjudications against a testifying defendant.	State argues the statute authorizes such impeachment.	Montgomery prohibits impeachment of a testifying defendant with juvenile adjudications.	No; 5-150(1)(c) does not override Montgomery absent proper interpretation.
Whether defendant opened the door to admitting the juvenile adjudication through his testimony.	State contends defendant's statements opened the door.	Defendant's testimony did not misstate his criminal history to open the door.	The door was not opened by defendant's testimony; admission was error.
Whether the erroneous admission was harmless beyond a reasonable doubt.	Even without the adjudication, there was sufficient evidence against Villa; any error was harmless.	The State relied on the impeached credibility; the verdict could be different without the adjudication.	The error was not harmless; reversal and remand for a new trial.
Whether the appellate court correctly addressed Montgomery and 5-150(1)(c) interactions.	State contends statute overrides Montgomery per the 1998 amendment.	Court should follow Montgomery; amendment changed law.	Court held 5-150(1)(c) is not in conflict with Montgomery; nonetheless the admission here was error.

Montgomery v. Illinois, 47 Ill.2d 510 (1971) (impeachment standards for prior adjudications; general rule against admitting juvenile adjudications against defendant)
Massie, 137 Ill.App.3d 723 (1985) (juvenile adjudications admissible only for witness impeachment under prior statutory interpretation)
Bunch, 159 Ill.App.3d 494 (1987) (open-door exception to Montgomery for admissibility of juvenile adjudications)
Kerns, 229 Ill.App.3d 938 (1992) (perspective on Montgomery and 5-150(1)(c) interaction)
Sneed, 274 Ill.App.3d 287 (1995) (statutory interpretation of 5-150(1)(c) with Montgomery)
Coleman, 399 Ill.App.3d 1150 (2010) (reconciles 5-150(1)(c) with Montgomery in Fourth District)
Harris, 231 Ill.2d 582 (2008) (defining an opened-the-door analysis for juvenile adjudications)
People v. Taylor, 221 Ill.2d 157 (2006) (discussion of juvenile justice reform affecting impeachment)