Public-domain · open source
OpenJurist

342 Ill. App. 3d 310

People v. Griffin

Appellate Court of Illinois

Decided July 30, 2003

This page is marked noindex.

Appellate Court of Illinois · decided 2003-07-30

Good law ✅— No negative treatment on recordhow we know

Decided 2003-07-30

How this case has been cited

Cited by 18 later decisions — most recently July 2022

16 state decisions

80200320102020decided

Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.

View the full empirical analysis of this case →

PRESIDING JUSTICE MYERSCOUGH,

¶1specially concurring:

¶2I agree with the majority’s finding that respondent forfeited her right to raise her objection to the State’s petition on appeal because she failed to object to the State’s petition in the trial court. I would have ended the analysis there. However, I concur in the majority’s result, but specially concur to attempt to reconcile the majority’s holding with the section of the statute under which respondent was found unfit.

¶3The trial court found respondent unfit under section 1(D) (q) of the Adoption Act (750 ILCS 50/l(D)(q) (West 2000)), which provides that a parent is unfit if:

“[t]he parent has been criminally convicted of aggravated battery, heinous battery, or attempted murder of any child.” 750 ILCS 50/1 (D)(q) (West 2000).

¶4In the present case, respondent was convicted of first degree murder of J.R. The legislature did not specifically list first degree murder in this section of the statute. It is logical to infer, however, that if a parent is criminally convicted of a greater offense — i.e., first degree murder — that offense would naturally encompass the lesser offenses enumerated.

¶5Black’s Law Dictionary defines “aggravated battery” as “[a] criminal battery accompanied by circumstances that make it more severe, such as the use of a deadly weapon or the fact that the battery resulted in serious bodily harm.” Black’s Law Dictionary 146 (7th ed. 1999). Certainly first degree murder meets that definition and was intended by the legislature to fall within the purview of this section of the statute as a basis for a finding of unfitness.

/342/illapp3d/310 · .json · Public domain