CRIMINAL In re Jonathan C.B. By Kerry J. Bryson, Office of the State Appellate Defender In August 2006, the minor was charged with attempt robbery and criminal sexual assault by use of force. In the Supreme Court, the minor argued that he was not proved guilty beyond reasonable doubt, that he was denied due process when he was shackled during his trial without an individualized determination of necessity under People v. Boose, 66 Ill. 2d 261 (1977), and that Section 5-101(3) of the Juvenile Court Act was unconstitutional because juveniles charged with sexual offenses have a constitutional right to a jury trial. In a 69-page opinion, the Court unanimously rejected the reasonable doubt claim in light of the standard of review requiring the court to take the evidence in the light most favorable to the prosecution and to give deference to the findings of the trier of fact, here, the trial judge. The Court split 4-3 on the shackling claim, with the majority concluding that it was forfeited and that the record did not support the minor’s claim of error.