People v. Jung

CHIEF JUSTICE HARRISON,

dissenting:

My colleagues have misrepresented the circumstances of this case. The statute invalidated by the trial court is section 11 — 501.4—1 of the Illinois Vehicle Code (625 ILCS 5/11 — 501.4—1 (West 1996)). In its appeal, however, the State directs its arguments to the validity of section 11 — 501.4 of the Illinois Vehicle Code (625 ILCS 5/11— 501.4 (West 1996)). Section 11 — 501.4—1 is not a subsection of section 11 — 501.4. They are separate provisions.

The argument portion of the State’s brief contains no “contentions of the appellant and the reasons therefor, with citation of the authorities,” as they pertain to section 11 — 501.4—1. The State’s analysis does not mention 11 — 501.4—1 at all. All arguments and citations to authority are directed instead to section 11 — 501.4, which has nothing to do with this case. With respect to section 11 — 501.4—1, the statute at issue here, the State’s brief is therefore in violation of Supreme Court Rule 341(e)(7) (177 Ill. 2d R. 341 (e)(7)), which is applicable to criminal appeals pursuant to Supreme Court Rule 612(i). 177 Ill. 2d R. 612(i); People v. Thomas, 116 Ill. 2d 290, 303-04 (1987).

The State’s failure to comply with Rule 341(e)(7) should be fatal to its appeal. A reviewing court is entitled to have issues clearly defined with pertinent authority cited and coherent arguments presented. Arguments inadequately presented are waived. See People v. Lantz, 186 Ill. 2d 243, 261-62 (1999); Spinelli v. Immanuel Lutheran Evangelical Congregation, Inc., 118 Ill. 2d 389, 401 (1987); Vernon Hills III Ltd. Partnership v. St. Paul Fire & Marine Insurance Co., 287 Ill. App. 3d 303, 311 (1997); see also Maun v. Department of Professional Regulation, 299 Ill. App. 3d 388, 399 (1998) (arguments that do not satisfy Rule 341(e)(7) do not merit consideration on appeal and may be rejected for that reason alone).

Although the State did eventually address arguments to the correct statutory section in its reply brief, those arguments came too late. Under Supreme Court Rule 341(e)(7), points not argued in the appellant’s brief are waived and cannot be raised for the first time in appellant’s reply brief. 177 Ill. 2d R. 341(e)(7); Sylvester v. Chicago Park District, 179 Ill. 2d 500, 507 (1997); Illinois Farmers Insurance Co. v. Cisco, 178 Ill. 2d 386, 395 (1997); People v. Thomas, 116 Ill. 2d at 304.

Because the State’s contentions as to section 11— 501.4 — 1 are not properly before us, analysis of the State’s position would require this court to speculate as to the nature of the arguments that could have been made, but were not. See In re Parentage of Janssen, 292 Ill. App. 3d 219, 228 (1997). A reviewing court will not become an advocate for, as well as the judge of, points the appellant seeks to raise. See Vernon Hills, 287 Ill. App. 3d at 311. The State should therefore be deemed to have forfeited its right to challenge the propriety of the circuit court’s judgment. See Cisco, 178 Ill. 2d at 395; Greer v. Illinois Housing Development Authority, 122 Ill. 2d 462, 516 (1988); Maun, 299 Ill. App. 3d at 399.

The State’s error was evident to this court when we heard oral argument. Why my colleagues have chosen to ignore it today is something only they can account for. Perhaps they believe some higher purpose will be served. Perhaps they want to spare the Attorney General’s office embarrassment. In either case, I cannot condone their actions.

The power to promulgate rules conferred on this court by the Illinois Constitution does not carry with it any concomitant right to disregard the rules whenever we are unhappy with the effect they will have in a particular case. To the contrary, as author of the rules, our court has a special duty to see that they are honored and obeyed in every case, regardless of the circumstances. We sit above all tribunals, save the United States Supreme Court. If this is to be a government of laws, not men, we, above all others, must set the example.

Our court should not be an adjunct to the prosecution or an apologist for the State. When the Attorney General’s office makes an error as fundamental as the one committed in this case, we do a disservice when we look the other way. Lawyers entrusted with responsibility for defending the laws of Illinois should at least be able to correctly identify what laws they are supposed to be defending. If something so basic is beyond their competence, what will happen when they are called upon to protect the interests of the people in cases where human life or public safety are at stake? The consequences could be disastrous.

The Attorney General’s office has suffered chronic personnel problems. Based upon requests for time extensions in other cases pending before our court, it appears that turnover is high and staffing inadequate. Work is not being completed as it should. In one instance, People v. Barrow, No. 80332, delays were so extreme that this court was forced to hold that the State had forfeited its right to file a brief.

The problem in this case may be symptomatic of these difficulties. When too few people are forced to do too much work, mistakes are inevitable. What can be done about this I do not know. That is a matter for the Attorney General alone. All I know is that if we say nothing and do nothing, the Attorney General will have no incentive to put things in proper order. The problems will continue unchecked. They will come back to confront us again, and the people of Illinois will be the worse for it.

For the foregoing reasons, the judgment of the circuit court of La Salle County should be affirmed. I therefore dissent.