The Illinois Supreme Court issued an opinion Thursday in *People v. Chambliss* that clarifies when constitutional violations in criminal proceedings can be reviewed on appeal despite a defendant's failure to object at trial. The court reversed the Fifth District Appellate Court's decision that had overturned aggravated battery convictions based on plain error review.
The case centers on defendant Anzano P. Chambliss, who was convicted of aggravated battery following an October 2021 incident outside a convenience store in DuQuoin. According to court records, Trevor Pullum and Chris Cates, employees at Pinckneyville Correctional Facility, witnessed Chambliss beating Emily Barnes and Carolyn Spell while driving home from work on Oct. 5, 2021. The two men stopped their vehicles and intervened to stop the attack.
DuQuoin Police Department Chief Steve Ingram and Officer Reid Bastien arrived at the scene shortly after and spoke with the victims. Chambliss was arrested that day and charged three days later on Oct. 8, 2021, with three counts of aggravated battery, a Class 3 felony.
The constitutional issue arose because the trial court failed to conduct what Article VI, Section 7 of the 1970 Illinois Constitution requires: a "prompt preliminary hearing to establish probable cause" in criminal cases. Chambliss never objected to the missing preliminary hearing at any point before his trial, where he was ultimately convicted beyond a reasonable doubt.
After conviction, Chambliss appealed, arguing that the trial court's failure to hold the constitutionally mandated preliminary hearing constituted reviewable error despite his failure to object. The Fifth District Appellate Court agreed with Chambliss in 2024, ruling that the constitutional violation amounted to second-prong plain error that affected the fairness and integrity of the judicial process. The appellate court reversed Chambliss's convictions based on this finding.
The Illinois Supreme Court disagreed with the appellate court's analysis. Justice Theis delivered the majority opinion for the court, with Justices Overstreet, Holder White, Cunningham, and Rochford concurring. The majority held that the trial court's failure to conduct the required preliminary hearing was not reviewable as second-prong plain error.
Under Illinois law, plain error review allows appellate courts to address unpreserved errors in limited circumstances. First-prong plain error applies when the evidence is closely balanced and the error might have affected the trial's outcome. Second-prong plain error applies when the error is so serious that it affected the fairness and integrity of the judicial process.
The Supreme Court's ruling suggests that not every constitutional violation automatically qualifies for second-prong plain error review, particularly when a defendant fails to raise the issue during trial proceedings. The decision reflects the court's emphasis on the importance of preserving objections and the limits of appellate review for unpreserved constitutional claims.
Justice O'Brien authored a dissenting opinion, joined by Chief Justice Neville. The dissent presumably argued that the constitutional violation was sufficiently serious to warrant plain error review, though the full text of the dissenting opinion was not included in the available records.
The case highlights the tension between ensuring constitutional protections in criminal proceedings and maintaining procedural requirements for preserving issues on appeal. Article VI, Section 7 of the Illinois Constitution requires prompt preliminary hearings to establish probable cause, serving as a safeguard against unfounded criminal prosecutions.
Preliminary hearings serve several important functions in the criminal justice system. They provide an early judicial determination of whether probable cause exists to believe a defendant committed the charged offense. They also offer defendants an opportunity to challenge the prosecution's case before trial and can help identify weaknesses in the state's evidence.
The Supreme Court's decision may have broader implications for how Illinois courts handle constitutional violations that go unpreserved at trial. The ruling suggests that defendants and their counsel must be vigilant about asserting constitutional rights during trial proceedings rather than relying on appellate courts to address such issues later.
For practitioners, the decision underscores the importance of making timely objections to preserve constitutional claims for appellate review. Defense attorneys must be particularly careful to identify and object to procedural violations, including failures to conduct required preliminary hearings, during the trial court proceedings.
The ruling also clarifies the boundaries of plain error review in Illinois criminal cases. While plain error doctrine provides some relief for unpreserved errors, the Supreme Court's decision indicates that not every constitutional violation will automatically qualify for such review, especially regarding procedural requirements that defendants could have raised during trial.
The case returns to the trial court level, where Chambliss's convictions for aggravated battery will stand. The defendant may pursue other avenues of appeal or post-conviction relief, though the Supreme Court's ruling significantly limits the available options for challenging the missing preliminary hearing.
This decision joins a line of Illinois Supreme Court cases that define the scope and limits of plain error review in criminal appeals, providing guidance for future cases involving unpreserved constitutional claims.