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State v. MA

124 Ill. 2d 135, 124 Ill. Dec. 511, 529 N.E.2d 492 (1988)

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State v. MA

Illinois Supreme Court

124 Ill. 2d 135, 124 Ill. Dec. 511, 529 N.E.2d 492 (1988)

Facts

MA (defendant) was arrested and charged with the unlawful use of weapons on school grounds. Although MA was a minor, an Illinois statute automatically transferred four specific charges against minors to adult criminal court: murder, aggravated sexual assault, armed robbery with a firearm, and unlawful use of weapons on school grounds. The weapons-at-school charges had been added to this list in an effort to target gang violence at schools, especially the gang tactic of using schoolchildren as gunmen because minors previously faced only juvenile-court charges if caught. However, the criminal court ruled that automatically transferring the weapons-at-school charges against MA to criminal court was unconstitutional. The state (plaintiff) appealed the ruling to the Illinois Supreme Court. On appeal, MA argued that the automatic-transfer statute violated his constitutional rights to (1) equal protection because minors who committed highly similar offenses, such as using weapons in public parks near schools, were treated differently and (2) substantive due process because the statute irrationally treated a weapons violation differently from other gang-related charges.

Rule of Law

Issue

Holding and Reasoning (Ryan, J.)

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