In an amended petition for adjudication of wardship, the State alleged that respondent committed two acts of aggravated criminal sexual abuse and one act of battery. The juvenile court found respondent guilty of all three charges and sentenced respondent to two years of probation and imposed the requirement that respondent have no unsupervised contact with any minor not related to him. On appeal, respondent argued that the juvenile court, under plain error review, committed a clear or obvious error by imposing a “no contact” condition of his probation. Respondent also argued that the battery adjudication should be vacated under the one-act, one-crime rule. The appellate court held that respondent did not establish that the juvenile court committed a clear or obvious error by not vacating the battery adjudication; however, the appellate court further found that trial counsel provided ineffective assistance of counsel by not challenging the “no contact” condition of probation. The appellate court vacated this condition of probation and remanded for entry of a revised order. (STEIGMANN and KNECHT, concurring)
Illinois Appellate Court
Civil Court
Juvenile Probation