Criminal Law

People v. Butler

Illinois Supreme Court
Criminal Court
Confrontation Clause
Citation
Case Number: 
2025 IL 130988
Decision Date: 
Thursday, November 20, 2025
Holding: 
Affirmed.
Justice: 
OVERSTREET

Defendant was found guilty and sentenced to consecutive terms of nine years for predatory criminal sexual assault of a child, nine years for aggravated criminal sexual assault, and three years for aggravated criminal sexual abuse for a total prison term of 21 years. The appellate court affirmed, finding that the trial court properly admitted out-of-court statements made by defendant’s younger sister and the victim during a video recorded, victim-sensitive interview because the victim testified and was available for cross-examination at trial. The supreme court also affirmed, finding that the victim’s availability as a witness at trial and being subjected to cross-examination did not violate the confrontation clause even though she testified that did not remember her prior statements. (NEVILLE, THEIS, HOLDER WHITE, CUNNINGHAM, and O’BRIEN, concurring. ROCHFORD took no part in the decision)

People v. Grayson

Illinois Supreme Court
Criminal Court
Mootness Doctrine
Citation
Case Number: 
2025 IL 131279
Decision Date: 
Thursday, November 20, 2025
Holding: 
Judgments vacated, appeal dismissed.
Justice: 
PER CURIAM

Defendant appealed from a circuit court order finding that he should be detained prior to trial. The appellate court reversed and the State appealed to the Illinois Supreme Court. During the pendency of the appeal, defendant’s case went to trial and he was found guilty of second-degree murder. The supreme court dismissed the appeal, finding that the trial rendered the detention question moot. The court further vacated the judgments of the appellate court and circuit court in order to preclude them from becoming precedent for future cases.

LIVE WEB - Preventing Tragedy: The Intersection of Karina's Law and Family Law

January 27, 2026
Presented by the ISBA Family Law Section
Co-presented by the ISBA Young Lawyers Division

Live Webcast
Tuesday, January 27, 2026
2:00 – 5:20 p.m.

3.0 hours MCLE credit

In June 2023, Karina Gonzalez reported to police that her estranged husband had threatened to kill her, which led to her being granted an Order of Protection that automatically revoked her husband’s FOID card. But that alone did not remove the guns from her husband’s possession and on July 3, Jose Alvarez shot and killed his wife and 15-year-old daughter. The legislation that followed – and was subsequently referred to as Karina’s Law – requires the confiscation of guns from people who have had their FOID cards revoked due to an Order of Protection against them. Karina’s Law was signed by Governor Pritzker on February 10, 2025 and became effective in May 2025. Don’t miss this in-depth look at how Karina’s Law is designed to prevent unnecessary tragedy, how the new law intersects with the family law practice, and how it strengthens existing laws by clarifying who is responsible for removing firearms once an Order of Protection is granted. Family law attorneys, criminal justice lawyers, and general practitioners with all levels of practice experience who attend this online program will learn:
  • How Karina’s Law grants law enforcement the authority to execute search warrants to seize firearms from alleged abusers;
  • How this new law supports the existing protections offered by a traditional Order of Protection;
  • How to correctly implement Karina’s Law to ensure that the individuals they represent are protected from potential tragedy; and
  • The case law and pleading options to be aware of.

Program Coordinator:
Pamela J. Kuzniar, Haid and Teich LLP, Chicago

Program Moderators:
Olivia K. Basu, Hammer Serna and Quinn LLC, Chicago
Hon. Tamika R. Walker, 17th Judicial Circuit Court

Program Chat Moderators:
Sally Kolb, Land of Lincoln Legal Aid, Champaign
Genevieve E. Miller, Beattie | Onorato Family Law, Chicago


2:00 – 3:00 p.m. Orders of Protection: An Overview
Join us for this comprehensive look at the pleadings, orders, and evidence that is needed to ensure that your client is protected from domestic violence. Topics include rights, restrictions, available remedies, civil and criminal processes, rehabilitation, and punishment, as well as the special considerations necessary when the perpetrator is a law enforcement professional or service member, and the additional remedies that may apply.
Heather Hurst, Davis Friedman, Chicago
Sally Kolb, Land of Lincoln Legal Aid, Champaign

3:00 – 4:00 p.m. Incorporating Gun Violence Protection into Your Family Law Practice
Gain a better understanding of why family law practitioners need to focus on gun violence prevention from initial intake through settlement or trial. Learn the alternative remedies to ensure that your client and their children are protected, including language for settlement agreements, options for firearm restraining orders in addition to (or in lieu of) a traditional Order of Protection, and the application of Karina’s Law. Gun violence trends and why family law practitioners should be aware are also discussed.
Stuart A. Reid, The Law Offices of Stuart A. Reid, P.C., Deerfield

4:00 – 4:15 p.m. Break

4:15 – 5:15 p.m. Karina’s Law: Mandates and Implementation
The time when victims seek and win an Order of Protection is statistically one of the most dangerous moments for them, and Karina’s Law ensures that guns are removed from abusers during these emergencies to safeguard victims from tragedy. This panel presentation discusses the differences between an Order of Protection issued under the Illinois Domestic Violence Act and those issued under the Illinois Criminal Statutes, as well as the mandates officers are to follow when serving/enforcing an Order of Protection, how to implement Karina’s Law, and the additional liability the officer now faces since this falls under the Illinois Domestic Violence Act. A look at how to word an order and what must be pled to secure the best possible outcome for the victim is also included.
Hon. Jennifer Clifford, 17th Judicial Circuit Court, Rockford
Nancy Donahoe, DuPage County Chief Assistant State’s Attorney, Wheaton
Hon. Megan Goldish, Domestic Violence Courthouse, Chicago
Hon. Ramona M. Sullivan
, Champaign County Circuit Court, Urbana

For best practices, before attending the program using ISBA's Zoom platform, please visit our Technical Support page.

Program Information

  • Fees:
    • ISBA Member - $90
      • ISBA sponsoring section members get a $10 registration discount (which is automatically calculated in your cart when you log in to register).
    • Non-Member - $210
    • New Attorney Member (within the first five years of practice) - $25
    • Law Student Members - Free
    • Special pricing is available for Legal Service Attorneys.
  • If you cannot attend the live web event, a full refund is available, if you cancel your registration up to the start of the live web event on the program page in your “My CLE Account”. 
  • Please Note: MCLE credit is available to registrants only on the day of this live event – and you must attend the entire program to earn MCLE credit. All registrants will receive access to a recording of the event a few days after the program, but credit is NOT available for the recording.

Sexual Harassment Prevention Training Course

ISBA Members: Use your 15 hours of Free CLE credits to order this program –
just use the green button next to the “Add to Cart” button below!

Presented by the ISBA Labor and Employment Section


1.0 hour MCLE credit


Original Program Date: November 18, 2022
Accreditation Expiration Date: ­­­­­­­­­­­­­­­­­­­­­­­­­November 19, 2027 (You must certify completion and save your certificate before this date to get MCLE credit)


This course satisfies the state-mandated training requirement!
Improve the culture of your office and satisfy your annually mandated sexual harassment prevention training requirement by attending this program. Consistent with the requirements established in Section 2-109(B) of the Illinois Workplace Transparency Act (Public Act 101-0220) this program will help you gain an understanding of what sexual harassment is, what remedies are available to victims of sexual harassment, and what responsibilities employers have in the prevention, investigation, and provision of corrective measures to address sexual harassment in the workplace. Topics include: reporting allegations; conditions of employment; settlement or termination agreements; and more. This program is open to both Illinois lawyers and their staff members.

Program Virtual Moderator:
Laura E. Schrick, Mathis, Marifian & Richter, Ltd., Belleville

Program Speakers:
Michael R. Lied, Attorney at Law, Dunlap
Thalia Pacheco
, Fish Potter Bolaños, P.C., Chicago


Pricing Information

  • Please Note: You must attend the entire program in order to earn MCLE credit for this seminar.
  • Fees:
    • ISBA Member Price of $35 is displayed below when you login and program is eligible for Free CLE member benefit
    • Non-Member Price $70
    • New Attorney Member (within the first five years of practice) - $25
    • Law Students - Free

People v. Thomas

Illinois Appellate Court
Criminal Court
Theft and Fraud
Citation
Case Number: 
2025 IL App (1st) 232035
Decision Date: 
Monday, November 17, 2025
District: 
1st Dist.
Division/County: 
5th Div./Cook Co.
Holding: 
Affirmed in part, reversed in part, remanded.
Justice: 
MIKVA

Defendant, the co-owner of a medical supply company, was accused of fraudulent Medicaid billing and after a bench trial was found guilty of theft based on the exertion of unauthorized control over the property of another, theft based on deception, and vendor fraud. The trial court merged the vendor fraud count into the theft by deception count and imposed concurrent prison terms of six years for theft by unauthorized control and six years for theft by deception. On appeal, defendant challenged the sufficiency of the evidence and argued that one of two theft convictions should be vacated under the one-act, one-crime doctrine. The appellate court affirmed in part and reversed in part and remanded to the trial court to determine which of each defendant’s two convictions, which the parties agreed were for the same criminal act, should stand, and to reduce the remaining conviction to a Class 1 felony because the State failed to prove the theft of governmental property. (MITCHELL and ODEN JOHNSON, concurring)

People v. Hughes

Illinois Appellate Court
Criminal Court
Standby Counsel
Citation
Case Number: 
2025 IL App (4th) 240514
Decision Date: 
Monday, November 17, 2025
District: 
4th Dist.
Division/County: 
Livingston Co.
Holding: 
Affirmed.
Justice: 
STEIGMANN

Defendant was found guilty of aggravated battery and was sentenced to 10 years in prison. During the trial, defendant represented himself and was removed two times from the courtroom for inappropriate behavior. On appeal, defendant argued that the trial court erred by failing to admonish him that if he were removed from the courtroom he would be unrepresented for those portions of the proceedings and that the trial court erred by failing to appoint standby counsel to represent defendant when he was not present. The appellate court affirmed under a plain error review, finding that the trial court repeatedly admonished defendant regarding the consequences of his continued misconduct and that appointment of standby counsel was not required under the facts of the case. (DeARMOND, concurring and DOHERTY, specially concurring)

People v. Sims

Illinois Appellate Court
Criminal Court
Overdose Prevention and Harm Reduction Act
Citation
Case Number: 
2025 IL App (4th) 250148
Decision Date: 
Monday, November 17, 2025
District: 
4th Dist.
Division/County: 
Adams Co.
Holding: 
Reversed and remanded.
Justice: 
KNECHT

In consolidated appeals, the appellate court considered whether the circuit court erred when it dismissed drug-related charges against the defendant by finding he was immune from prosecution pursuant to the Overdose Prevention and Harm Reduction Act. On appeal, the State argued that defendant failed to prove that the used drug paraphernalia in which the drugs were found came from a program established under the Act. The appellate court reversed and remanded for further proceedings, finding that defendant failed to make the requisite minimum showing that would entitle him to immunity under the Act. (DOHERTY and DeARMOND, concurring)

Jannke v. Gierach

Federal 7th Circuit Court
Criminal Court
Federal Habeas Relief
Citation
Case Number: 
No. 23-2485
Decision Date: 
November 17, 2025
Federal District: 
W.D. Wis.
Holding: 
Affirmed.
Judge: 
ST. EVE

Petitioner, who is in state prison after being convicted of first-degree reckless homicide, filed a federal habeas petition raising a claim of ineffective assistance of counsel. The Seventh Circuit affirmed, finding that petitioner failed to exhaust his claim at each level of the state judiciary before seeking federal habeas relief and that the district court properly dismissed petitioner’s claim based on procedural default. (EASTERBROOK and ROVNER, concurring)

LIVE WEB - Fred Lane's Trial Techniques Institute - Spring Semester 2026

February 24, 2026 to June 30, 2026
Presented by the Illinois State Bar Association

 



Live Webcast
Tuesday, February 24, 2026 – Tuesday, June 30, 2026
Each Tuesday: 5:15 – 6:45 p.m.

27.0 hours MCLE credit, including 27.0* hours Professional Responsibility in the following category: Professionalism, Civility, Legal Ethics, or Sexual Harassment Prevention credit

Improve your trial skills in this “learn-by-doing” program that covers all phases of trial work from both a plaintiff/prosecutor and defendant’s viewpoint, in both civil and criminal cases. Through this course, you will learn and practice new trial techniques that are most effective and consistent with the Illinois Rules of Evidence and the Federal Rules of Evidence. Each session is audio-video taped so you can see and hear the improvements in your voice, manner, and trial technique. The course has been proven to be of value whether your practice includes trying jury and non-jury cases, administrative hearings, arbitrations, or even mediations.

Fred Lane’s Trial Technique Institute consists of two semesters and runs approximately four months per semester. We are offering the Spring 2026 Semester as a stand-alone option via Zoom to make it available to all Illinois attorneys. Classes take place each Tuesday evening from 5:15 – 6:45 p.m. Breaks for holiday consideration do exist.

 

  • Spring Semester: February – June
  • Fall Semester: September – January

 


Spring Semester topics include:

 

  • An overview of the principles of communication, argument and persuasion on behalf of the plaintiff/prosecutor and defendant.
  • Jury Selection
  • Making winning Opening Statements/Closing Arguments to the jury in various type of cases, such as:
    • Personal Injury Case (Motor vehicle malpractice, product liability, attractive nuisance, federal employers’ liability, wrongful death, suits against municipalities, dram shops, airline cases, etc.)
    • Contract Cases (Goods, wares and merchandise, breach of contract, real estate broker’s commission, and life insurance)
    • Special Actions (Will contests, assault and battery, slander, malicious prosecution, false arrest and imprisonment)

 

About the Speakers:
Scott Lane is a partner of the firm of Lane Brown, LLC, a plaintiff’s personal injury firm in Chicago, Prior to his present practice, Scott was a Cook County Assistant State’s Attorney for several years. He is an Adjunct Professor at the Loyola University of Chicago of Law where he is a founding member of Loyola’s Circle of Advocates and has coached their Trial Team. Scott frequently lectures at bar association seminars and has authored numerous articles, chapters, and texts pertaining to various aspects of civil litigation and trial technique. He is a contributing author and editor to “Lane’s Goldstein Trial Technique” and “Lane Medical Litigation Guide” and co-authored the book, “Illinois Motions in Limine”. Scott has been consistently selected as an “Illinois Super Lawyer” as published by the Law & Politics and Chicago Magazine, and in 2014 he became a member of The National Trial Lawyers: Top 100.

Fred Lane , the original founder of this course, will serve as an occasional guest instructor. Mr. Lane is a former Assistant State’s Attorney and has had over 40 years of litigation experience. Mr. Lane is a lecturer and author on Trial Technique Subject: author of Lane’s Goldstein Trial Technique (3 vols.): editor of Medical Trial Technique Quarterly : author of Lane Medical Litigation Guide (4 vols.): author of Lane’s Goldstein Litigation Forms (3 vol.). He is the co-author of Lane & Calkins Mediation Practice Guid e and co-founder of the International Academy of Dispute Resolution. Mr. Lane is also past president of the following organizations and associations: Illinois Trial Lawyers Association: Diplomat and Past President of the American Board of Trial Advocates IL; Fellow of the International Academy of Trial Lawyers, Past President of the Illinois State Bar Association: and Past President of the Decalogue Society of Lawyers.

*Professional Responsibility MCLE credit subject to approval

 

 

 

Pricing Information

Fees:
  • ISBA Member - $450
  • Non-Member - $750