People v. J.F.

Illinois Appellate Court
Civil Court
Juvenile Court Act
Citation
Case Number: 
2014 IL App (1st) 123579
Decision Date: 
Wednesday, May 7, 2014
District: 
1st Dist.
Division/County: 
Cook Co., 3d Div.
Holding: 
Affirmed in part and vacated in part.
Justice: 
HYMAN
(Court opinion corrected 5/13/14.) Respondent, then age 15, was adjudicated delinquent for a forcible felony, for attack by group of girls on another girl on CTA el train. Court violated one-act, one-crime doctrine by finding Respondent delinquent of both aggravated battery and simple battery for striking and biting victim. As both adjudications resulted from same physical act, court should not have found her delinquent of both, but should have vacated less serious offense of battery. Mandatory minimum probation term of five years for robbery does not violate equal protection clause, as Respondent cannot establish she is similarly situated to juveniles who commit nonforcible felonies or that a criminal conviction of adult offender equates to a finding of delinquency. (NEVILLE and MASON, concurring.)