MOTION TO DECLARE ILLINOIS APPELLATE COURT ACT AND SUPREME COURT RULE 317 UNCONSTITUTIONAL AND MEMORANDUM OF SUPREME COURT JURISDICTION

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Case No. 2014 IL ________
IN THE SUPREME COURT OF ILLINOIS

People of the State of Illinois, ) Appeal from the Appellate Court, Second
Appellee - Plaintiff ) Judicial District, Case No. 2-12-0688
)
) Circuit Court of the Nineteenth Judicial
v. ) Circuit, Lake County, Illinois
) Case No. 07 CM 8549
)
Christopher Briggs, ) Honorable Michael Betar, Presiding
Appellant - Defendant ) Trial Judge.

MOTION TO DECLARE ILLINOIS APPELLATE COURT ACT AND
SUPREME COURT RULE 317 UNCONSTITUTIONAL AND
MEMORANDUM OF SUPREME COURT JURISDICTION
As a threshold matter the Appellate Court by not judicially hearing my appeal and allowing
a non-judicial ministerial court clerk to hear my judicial case, render judicial orders, and final
judgment has, at a bare minimum, violated my constitutional due process right to be heard
judicially. This is a question under the Constitution of the United States or of this State which arises
for the first time in and as a result of the action of the Appellate Court.
The clerk has no judicial power. Livingston County Building & Loan Ass'n v. Keach, 213 Ill.
59, 60, 72 N.E. 769, 770 (Ill., 1904); Ill. Const.1970, Article VI, § 18(b) (―clerks and other non-
judicial officers‖).
Illinois Rules of Evidence Rule 201 imposes a mandatory and nondiscretionary duty on the
court requiring the court take judicial notice when Rule 201(d) states: ―When Mandatory. A court
shall take judicial notice if requested by a party and supplied with the necessary information.‖
Illinois Rules of Evidence, Article II, Rule 201(d) (West 2014).
Appellant requests and the court mandatorily shall take judicial notice of the fact that all
orders in case 2-12-0688 (Exhibit 1) are unsigned and appear in the name of Clerk Robert J.
Mangan.
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This court's jurisdiction is defined by section 4 of article VI of the Illinois Constitution, which
is helpfully entitled ―Supreme Court—Jurisdiction.‖ Ill. Const. 1970, art. VI, § 4. Subsection (a)
defines our original jurisdiction, subsection (b) defines our jurisdiction over direct appeals from the
circuit court, and subsection (c) establishes our jurisdiction to hear appeals from the appellate
court. See Ill. Const. 1970, art. VI, §§ 4(a), (b), (c). Therefore, because the instant case involves an
appeal from the appellate court, subsection (c) is the only relevant provision. Accordingly, I believe
it is worth setting out in its entirety: ―Appeals from the Appellate Court to the Supreme Court are a
matter of right if a question under the Constitution of the United States or of this State arises for the
first time in and as a result of the action of the Appellate Court, or if a division of the Appellate
Court certifies that a case decided by it involves a question of such importance that the case
should be decided by the Supreme Court. The Supreme Court may provide by rule for appeals
from the Appellate Court in other cases.‖ (Emphasis in original.) Wauconda Fire Protection Dist. v.
Stonewall Orchards, LLP, 214 Ill.2d 417, 444-45, 828 N.E.2d 216, 232 (Ill., 2005); Yellow Cab Co.
v. Jones, 108 Ill.2d 330, 338, 483 N.E.2d 1278, 1282 (Ill., 1985); Ill. Const. 1970, art. V I, § 4(c).
Our Constitution‘s words are clear, unambiguous and need no interpretation. The
constitutional provision at issue here provides that: ―The Supreme Court may provide by rule for
appeals from the Appellate Court in other cases.‖ Ill. Const.1970, art. VI, § 4(c). Stated differently:
When a constitutional question arises for the first time in and as a result of the action of the
appellate court an appeal to the Supreme Court is a matter of constitutional right and rules do not
apply and rules may not interfere with the constitutionally protected right.
The above provision is quite clear. ―In other cases‖ than appeals as of right, we have
―jurisdiction‖ over appeals as we ―provide by rule.‖ (Emphasis in original.) Wauconda Fire
Protection Dist. v. Stonewall Orchards, LLP, 214 Ill.2d 417, 445, 828 N.E.2d 216, 232 (Ill., 2005).
Constitutional provisions which are plain and explicit on their face, the meaning of which is
clearly apparent, permit of no construction by the courts. Yellow Cab Co. v. Jones, 108 Ill.2d 330,
336, 483 N.E.2d 1278, 1281 (Ill., 1985), citing DeBruyn v. Elrod , 84 Ill.2d 128, 134, 418 N.E.2d
413, 416 (Ill., 1981).
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―[T]he doctrine is firmly established, that where the words employed, when taken in their
ordinary, natural signification, and the order of their grammatical arrangement given them by the
framers, embody a definite meaning which involves no conflict with other parts of the same
instrument, then that meaning which is apparent upon the face of the instrument is the only one we
are at liberty to say was intended to be conveyed, and there is no room for construction. * * * When
a particular act is inhibited by the clear and unambiguous language of the constitution, the policy of
such inhibition, or the inconvenience that may ensue its enforcement, is a matter with which the
court has no concern; its duty is simply to reverently recognize and faithfully enforce.‖ DeBruyn v.
Elrod, 84 Ill.2d 128, 135, 418 N.E.2d 413, 416 (Ill., 1981), quoting Hills v. City of Chicago, 60 Ill. 86,
90-91 (Ill., 1871).
As this court has observed: ‗The constitution is the supreme law * * * and every court is
bound to enforce its provisions.‘ Chicago Bar Ass'n v. Illinois State Bd. of Elections, 161 Ill.2d 502,
508, 641 N.E.2d 525, 528 (Ill., 1994), quoting Coalition I, 65 Ill.2d 453, 460, 359 N.E.2d 138, 141
(Ill., 1976), in turn quoting People ex rel. Miller v. Hotz, 327 Ill. 433, 437, 158 N.E. 743, 745 (Ill.,
1927).
However, Illinois Supreme Court Rule 317 entitled: ―Appeals from the Appellate Court to
the Supreme Court as of Right‖, unconstitutionally adds additional requirements not found in our
Constitution‘s appeal as a matter of right contained in Article VI, § 4(c). Rule 317 unconstitutionally
adds pre-conditional appeal terms: ―Appeals from the Appellate Court shall lie to the Supreme
Court as a matter of right in cases in which *** a question under the Constitution of the United
States or of this state arises for the first time in and as a result of the action of the Appellate Court.
The appeal shall be initiated by filing a petition *** If the court allows the petition, briefs, and
abstracts in cases in which they are required, shall be filed…‖ (Emphasis added.) ILCS S. Ct. Rule
317 (West 2014).
In Illinois, jurisdiction is conferred by the constitution. People v. Davis, 156 Ill.2d 149, 156,
619 N.E.2d 750, 754 (Ill., 1993).
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A court cannot, by its rules, divest itself of, limit or restrict the jurisdiction conferred on it by
law. Pisa v. Rezek's Estate, 108 Ill.App. 198, 202 (1 Dist., 1903).
Illinois Supreme Court Rule 317 is facially unconstitutional, as requiring one with an appeal
as a matter of a constitutional right to petition the Supreme Court for permission to exercise the
right expressly granted by our Illinois Constitution of 1970 in Article VI, § 4(c).
[C]ourts, as well as other departments, are bound by that instrument. Marbury v. Madison,
5 U.S. 137, 180, 2 L.Ed. 60 (U.S., 1803).
The Illinois Judiciary, in enacting Supreme Court Rule 317, has unconstitutionally granted
itself arbitrary power to deny the constitutionally protected right to be heard on appeal at the Illinois
Supreme Court as granted by our Constitution in Article VI, § 4(c) thereby also interfering with the
Fourteenth Amendment due process right to be heard.
The opportunity to be heard is an essential requisite of due process of law in judicial
proceedings. Richards v. Jefferson County, Ala., 517 U.S. 793, 797, 116 S.Ct. 1761, 1765 (U.S.,
1996), citing Windsor v. McVeigh, 93 U.S. 274, 277, 23 L.Ed. 914 (U.S., 1876), Louisville &
Nashville R.R. Co. v. Schmidt, 177 U.S. 230, 236, 20 S.Ct. 620, 622, 44 L.Ed. 747 (U.S., 1900),
Simon v. Craft, 182 U.S. 427, 436, 21 S.Ct. 836, 839, 45 L.Ed. 1165 (U.S., 1901).
‗An unconstitutional law is void, and is as no law.‘ Fay v. Noia, 372 U.S. 391, 408, 83 S.Ct.
822, 832 (U.S., 1963), quoting Ex parte Siebold, 100 U.S. 371, 376, 25 L.Ed. 717 (U.S., 1879); Ex
parte Royall, 117 U.S. 241, 248, 6 S.Ct. 734, 738, 29 L.Ed. 868 (U.S., 1886); Reynoldsville Casket
Co. v. Hyde, 514 U.S. 749, 760, 115 S.Ct. 1745, 1752, 131 L.Ed.2d 820 (U.S., 1995) (a law
repugnant to the Constitution ―is void, and is as no law.‖ (concurring opinion, quoting Siebold )).
‗Especially is it competent and proper for this court to consider whether its proceedings are
in conformity with the Constitution and laws, because, living under a written constitution, no branch
or department of the government is supreme; and it is the province and duty of the judicial
department to determine in cases regularly brought before them, whether the powers of any branch
of the government, and even those of the legislature in the enactment of laws, have been
exercised in conformity to the Constitution; and if they have not, to treat their acts as null and void.‘
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Powell v. McCormack, 395 U.S. 486, 506, 89 S.Ct. 1944, 1956, 23 L.Ed.2d 491 (U.S., 1969),
quoting Kilbourn v. Thompson, 103 U.S. 168, 199, 26 L.Ed. 377 (U.S., 1880).
Our Supreme Court rulemaking authority arises from the Illinois Constitution of 1970,
Article VI, § 16, giving the Court constitutional power to modify its rules. See In re B.C.P., 2013 IL
113908, 8, 990 N.E.2d 1135, 1138 (Ill., 2013).
Rules of court must not be contrary to the constitution. Kinsley v. Kinsley, 388 Ill. 194, 198,
57 N.E.2d 449, 451 (Ill., 1944), citing People ex rel. Chicago Bar Ass'n v. Feinberg, 348 Ill. 549,
556, 181 N.E. 437, 440 (Ill., 1932) (Rules must, of course, be consistent with the law.)
Further, Illinois Appellate Court Act 705 ILCS 25/8.2 is also facially unconstitutional, with
the words of our Illinois Constitution‘s Article VI, § 4(c) changed from ―or‖ to ―and‖, thereby
requiring judicial approval of an appeal as a matter of constitutional right.
It should be noted at the outset that the supreme law of this State, the Illinois Constitution,
in Article VI, § 4(c) delineates an appeal as a matter of right as distinct and separate from a court‘s
certification of legal questions, when the words of Article VI, § 4(c) use the disjunctive ―or‖ and not
the conjunctive ―and‖ as used in the Appellate Court Act (705 ILCS 25/8.2). The Act
unconstitutionally interferes by imposing additional conditions on an appeal as a matter of right
created by our Constitution‘s Article VI, § 4(c).
The words of the Illinois Appellate Court Act in Section 8.2 track the words of our
Constitution‘s Article VI, § 4(c) verbatim except for changing the word ‘or‘ to ‗and‘: ―Appeals from
the appellate court shall lie to the Supreme Court as a matter of right only (a) in cases in which a
question under the Constitution of the United States or of this state arises for the first time in and
as a result of the action of the appellate court, and (b) upon the certification by a division of the
appellate court that a case decided by it involves a question of such importance that it should be
decided by the Supreme Court. The Supreme Court may provide by rule for appeals from the
appellate court in other cases.‖ Illinois Appellate Court Act (705 ILCS 25/8.2) (West 2014).
[c]onstitutional right cannot be made to depend upon a statute. People v. Hryciuk, 36 Ill.2d
500, 503, 224 N.E.2d 250, 251 (Ill., 1967).
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The General Assembly cannot enact legislation that conflicts with specific provisions of the
constitution, unless the constitution specifically grants the legislature that authority. O'Brien v.
White, 219 Ill.2d 86, 100, 846 N.E.2d 116, 124 (Ill., 2006), citing See, e.g., Thies v. State Board of
Elections, 124 Ill.2d 317, 325–26, 529 N.E.2d 565, 569 (Ill., 1988).
Since Marbury v. Madison, 1803, 1 Cranch 137, 2 L.Ed. 60, courts have recognized that
where the constitution and a statute are in conflict, the constitution prevails. People ex rel. Keenan
v. McGuane, 13 Ill.2d 520, 532, 150 N.E.2d 168, 175 (Ill., 1958).
Illinois Appellate Court Act (705 ILCS 25/8.2) violates an appeal as a matter of
constitutional right by granting the Illinois Judiciary discretion to deny certification thereby
circumventing a constitutional appeal as a matter of right created by our Constitution in Article VI,
§ 4(c). This is unequivocally unconstitutional on its face.
[t]he legislature cannot enact a statute that overrides or circumvents the constitution. Davis
v. Brown, 357 Ill.App.3d 176, 183, 827 N.E.2d 508, 515 (2 Dist., 2005), citing see Chicago Bar
Ass'n v. Department of Revenue, 163 Ill.2d 290, 297, 644 N.E.2d 1166, 1170 (Ill., 1994).
Further, any legislative action which is contrary to the Constitution is void. Rockford
Memorial Hosp. v. Department of Human Rights, 272 Ill.App.3d 751, 763, 651 N.E.2d 649, 659 (2
Dist., 1995), citing See In re Tingle, 52 Ill.App.3d 251, 256, 367 N.E.2d 287, 292 (1 Dist., 1977)
(Any legislative action contrary to the constitution ―is unconstitutional and void.‖)
[w]here it is clear that a limitation or restriction imposed by the people in the fundamental
law has been violated or disregarded by the General Assembly or any other authority whatever, it
is the plain duty of the court to so declare, and that duty can neither be evaded nor neglected in the
case of an act of the General Assembly, no matter how desirable or beneficial the attempted
legislation may be. (Emphasis added.) Sutter v. People's Gas Light & Coke Co., 284 Ill. 634, 640-
41, 120 N.E. 562, 565 (Ill., 1918)
The Constitution is supreme, and, whatever the purpose of the people may have been in
imposing a restriction upon legislation, it must be obeyed. Board of Trustees of Jr. College Dist.
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No. 521, Jefferson Counties, 24 Ill.App.3d 183, 185, 321 N.E.2d 127, 128 (5 Dist., 1974), quoting
Sutter v. People's Gas Light & Coke Co., 284 Ill. 634, 640-41, 120 N.E. 562, 565 (Ill., 1918).
A statute which is facially invalid has no force and effect upon any person or entity
regardless of the specific circumstances. People v. Nance, 189 Ill.2d 142, 146, 724 N.E.2d 889,
891 (Ill., 2000), citing In re Marriage of Lappe, 176 Ill.2d 414, 439, 680 N.E.2d 380, 392 (Ill., 1997).
An unconstitutional legislative enactment is void. See, Ex parte Young, 209 U.S. 123, 159,
28 S.Ct. 441, 454, 52 L.Ed. 714 (U.S., 1908).
The Illinois Appellate Court Act (705 ILCS 25/8.2) unconstitutionally allows an appeal as a
matter of right, as expressly granted by our Constitution in Article VI, § 4(c) only after the very
same court, that has caused a question under our Constitution(s) or an important legal question to
be presented as a result of the action of the Appellate Court, certifies its own actions as legally
important. The Act unconstitutionally grants an appellate court discretion to interfere with or deny
an appeal in diametric opposition to an appeal as a matter of right as granted by our Constitution in
Article VI, § 4(c).
Courts are the mere instruments of the law, and can will nothing. When they are said to
exercise a discretion, it is a mere legal discretion, a discretion to be exercised in discerning the
course prescribed by law; and, when that is discerned, it is the duty of the Court to follow it. Osborn
v. Bank of U.S. 22 U.S. 738, 866, 6 L. Ed. 204 (U.S., 1824).
‗It is a most extraordinary doctrine that the court has a discretion to enforce or not enforce
a provision of the constitution according to its judgment as to its wisdom or whether the public good
will be subserved by disregarding it.‘ Coalition I, 65 Ill.2d 453, 460, 359 N.E.2d 138, 141 (Ill., 1976),
quoting People ex rel. Miller v. Hotz, 327 Ill. 433, 437, 158 N.E. 743, 745 (Ill., 1927).
The Appellate Court Act (705 ILCS 25/8.2) gives a court colorable authority to act in a
manner that causes a question under our Constitution(s), legally affecting a party, to then review its
own actions and/or deny certification unconstitutionally interfering with an appeal to the Illinois
Supreme Court as a matter of constitutional right.
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‗justice must satisfy the appearance of justice.‘ In re Murchison, 349 U.S. 133, 136, 75
S.Ct. 623, 625 (U.S., 1955), quoting Offutt v. United States, 348 U.S. 11, 14, 75 S.Ct. 11, 13 (U.S.,
1954).
Constitutional concerns are greatest when the State attempts to impose its will by force of
law. Harris v. McRae, 448 U.S. 297, 315, 100 S.Ct. 2671, 2687 (U.S., 1980).
If one puts aside for a moment the legal issue that Supreme Court Rule 317 and the Illinois
Appellate Court Act unconstitutionally interfere with an appeal as a matter of constitutional right
and focuses their attention on the judicial conduct Canons found in our Illinois Code of Judicial
Conduct, ethical questions suddenly appear: Is it fundamentally fair to a party legally affected as a
result of the action of the appellate court to allow the same judges to decide whether their own
actions are important enough to them or it whether it advances their overall objective to be
reviewed by another court?
‗A fair tribunal is a basic requirement of due process.‘ Withrow v. Larkin, 421 U.S. 35, 46,
95 S.Ct. 1456, 1464 (U.S., 1975), quoting In re Murchison, 349 U.S. 133, 136, 75 S.Ct. 623, 625,
99 L.Ed. 942 (U.S., 1955); Scott v. Department of Commerce and Community Affairs, 84 Ill.2d 42,
54, 416 N.E.2d 1082, 1089 (Ill., 1981).
As we perceive the overarching issue on appeal impacts the actions of the judges
involved, we are compelled to consider the Code of Judicial Conduct and its canons provided in the
supreme court rules. Recognizing that the canons are incorporated in the supreme court rules we
are mindful of the supreme court's directive that its rules are not aspirational, have the force of law,
and should be adhered to as written. Stewart v. Lathan, 401 Ill.App.3d 623, 627, 929 N.E.2d 1238,
1242 (1 Dist., 2010), citing See Bright v. Dicke, 166 Ill.2d 204, 210, 652 N.E.2d 275, 277–78 (Ill.,
1995).
Supreme Court Rule 63, Canon 3, provides: ―(4) A judge shall accord to every person who
has a legal interest in a proceeding, or that person's lawyer, the right to be heard according to law.‖
Stewart v. Lathan, 401 Ill.App.3d 623, 627, 929 N.E.2d 1238, 1242 (1 Dist., 2010).
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The legal mind will ask: What Illinois court that intentionally fails to apply our
Constitution(s) and Laws during its proceedings by having its non-judicial ministerial clerk hear
judicial matters, create judicial orders, and final judgment as evidenced case 2-12-0688, will
suddenly become law abiding, reverse course, and certify their constitutional violations to a higher
court for review? Both the law and equity know the answer, and of course provide rights and
remedies for the injuries.
The Appellate Court is equally bound with every other court to observe and regard
constitutional rights of a litigant, and a writ of error from this court to the Appellate Court will lie on
the ground that it has disregarded or violated constitutional rights. People v. Powers, 283 Ill. 438,
440, 119 N.E. 421, 422 (Ill., 1918), citing Sixby v. Chicago City Ry. Co., 260 Ill. 478, 481, 103 N.E.
249, 250 (Ill., 1913).
What person could be surprised by the fact that my MOTION TO CERTIFY LEGAL
QUESTIONS THAT SHOULD BE DECIDED BY THE SUPREME COURT, filed in the Appellate
Court, was denied by an unsigned order (Exhibit 2) created by a non-judicial Appellate Court Clerk
with the legal effect of denying certification of important legal questions and thereby denying our
Constitution‘s Article VI, § 4(c) due process right to be heard by the Illinois Supreme Court? It
would appear that the judges and clerks of our Illinois courts are the foxes acting as gatekeepers
guarding against access to our courts.
―[t]he touchstone of due process is protection of the individual against arbitrary action of
government‖ County of Sacramento v. Lewis, 523 U.S. 833, 845, 118 S.Ct. 1708, 1716, 140
L.Ed.2d 1043 (U.S., 1998), quoting Wolff v. McDonnell, 418 U.S. 539, 558, 94 S.Ct. 2963, 2976, 41
L.Ed.2d 935 (U.S., 1974).
Our Illinois Constitution in Article VI, § 4(c) has made an appeal to the Supreme Court a
matter of right if a constitutional question arises for the first time in and as a result of the action of
the Appellate Court.

That is, a party has a right to have his case heard by the Illinois Supreme
Court and ―need not petition that court for an exercise of its discretion to allow him to bring the case
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before the court.‖ See e.g. Coppedge v. United States, 369 U.S. 438, 441-42, 82 S.Ct. 917, 919, 8
L.Ed.2d 21, 26 (U.S., 1962).
With the Appellate Court Act and Rule 317 the sovereign has usurped our Illinois
Constitution by giving itself the discretion to deny an appeal as a matter of constitutional right, by
withholding certification at the Appellate Court or by requiring a petition for leave to appeal at the
Supreme Court. This is factually exactly what has occurred in this case. The Appellate Court has
been motioned to certify legal questions and has denied certification (Exhibit 2), violating my
constitutional right to be heard on appeal. Further, after my Notice of Appeal was filed, the Illinois
Supreme Court in direct violation our Constitution‘s appeal as a matter of right as granted in Article
VI, § 4(c) has refused to docket or hear my case.
―[f]or an agent of the State to pursue a course of action whose objective is to penalize a
person's reliance on his legal rights is ‗patently unconstitutional.‘ ‖ Bordenkircher v. Hayes, 434
U.S. 357, 363, 98 S.Ct. 663, 668, 54 L.Ed.2d 604 (U.S., 1978), quoting Chaffin v. Stynchcombe,
412 U.S. 17, 32–33, n. 20, 93 S.Ct. 1977, 1986, n. 20, 36 L.Ed.2d 714), see U. S. v. Goodwin, 457
U.S. 368, 372, 102 S.Ct. 2485, 2488 (U.S., 1982).
An appeal is perfected when the notice of appeal is filed in the lower court, and no other
step in the perfecting of an appeal is jurisdictional. People ex rel. Sandberg v. Grabs, 373 Ill. 423,
427, 26 N.E.2d 494, 497 (Ill., 1940).
Jurisdiction is the right to hear and determine; not to determine without hearing. Windsor v.
McVeigh, 93 U.S. 274, 284 (U.S., 1876).
In a noncapital case, an appeal is perfected by filing a notice of appeal, and ―The only
requirements a defendant must meet for perfecting his appeal are those expressed as time
limitations within which various procedural steps must be completed‖ People v. Ross, 229 Ill.2d
255, 263, 891 N.E.2d 865, 871 (Ill., 2008), quoting Coppedge v. United States, 369 U.S. 438, 442,
82 S.Ct. 917, 919, 8 L.Ed.2d 21, 26 (U.S., 1962). People v. Lewis, 234 Ill.2d 32, 37, 912 N.E.2d
1220, 1223 (Ill., 2009); Brehm v. Piotrowski, 409 Ill. 87, 90, 98 N.E.2d 725, 727 (Ill., 1951) (Filing of
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a notice of appeal within due time causes jurisdiction of the reviewing court to attach instanter and
deprives the lower court of jurisdiction).
Therefore, by operation of law, the Illinois Supreme Court in the instant case has
jurisdiction that has been transferred to it from the Appellate Court pursuant to the Notice of Appeal
(Exhibit 3) filed as a matter of constitutional right.
―The existence of the jurisdiction creates an implication of duty to exercise it.‖ Howlett By
and Through Howlett v. Rose, 496 U.S. 356, 370, 110 S.Ct. 2430, 2440 (U.S., 1990), quoting
Mondou v. New York, N.H. & H.R. Co., 223 U.S. 1, 58, 32 S.Ct. 169, 178, 56 L.Ed. 327 (U.S.,
1912), further citing see Testa v. Katt, 330 U.S. 386, 67 S.Ct. 810, 91 L.Ed. 967 (U.S., 1947),
Missouri ex rel. St. Louis, B. & M.R. Co. v. Taylor, 266 U.S. 200, 208, 45 S.Ct. 47, 48, 69 L.Ed. 247
(U.S., 1924), Robb v. Connolly, 111 U.S. 624, 637, 4 S.Ct. 544, 551, 28 L.Ed. 542 (U.S., 1884).
The Court with jurisdiction transferred to it pursuant to an appeal filed as a matter of right
as granted by our Illinois Constitution in Article VI, § 4(c) is the Illinois Supreme Court. The Justices
of the Illinois Supreme Court have not docketed or heard my case in direct violation of my due
process right to be heard on appeal as granted by our Illinois Constitution in Article VI, § 4(c).
[t]he Due Process Clause was intended to prevent government officials ― ‗ ―from abusing
[their] power, or employing it as an instrument of oppression.‖ ‘ ‖ Collins v. Harker Heights, 503
U.S. 115, 126, 112 S.Ct. 1061, 1069, 117 L.Ed.2d 261 (U.S., 1992) (quoting DeShaney v.
Winnebago County Dept. of Social Servs., 489 U.S. 189, 196, 109 S.Ct. 998, 1003 (U.S., 1998) (in
turn quoting Davidson v. Cannon, 474 U.S. 344, 348, 106 S.Ct. 668, 670–671 (U.S., 1986). County
of Sacramento v. Lewis, 523 U.S. 833, 846, 118 S.Ct. 1708, 1716-1717, 140 L.Ed. 1043 (U.S.,
1998).
After filing my Notice of Appeal (Exhibit 3) as a matter of constitutional right and by
operation of law transferring jurisdiction, the Illinois Supreme Court Justices with Clerk ‗Lisa‘ acting
as their proxy, telephoned me on April 23
rd
at 10:33AM with the ‗legal advice‘ that, quote: ―my
appeal was not proper‖ and subsequently the Court mailed to me a letter that states: ―we [the
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Clerk] are enclosing a pro se template to guide you while preparing your petition for leave to
appeal.‖ (Exhibit 4)
In other words, according to our Illinois Supreme Court‘s Justices unsupported legal
conclusions, masquerading as ‗legal advice‘ emanating from their non-judicial ministerial Court
Clerk, a party with an appeal as a matter of constitutional right must first petition the Illinois
Supreme Court for permission to exercise that constitutional right. Fascinating.
Jurisdiction is the right to hear and decide, and it must be exercised. Overby v. Gordon,
177 U.S. 214, 221, 20 S.Ct. 603, 606, 44 L.Ed. 741 (U.S., 1900).
I must thank the Justices of our Supreme Court for their irrational exuberance and
unsupported ‗legal advice‘ attempting to dissuade me from exercising my appeal as a matter of
constitutional right coming from a Court with jurisdiction that refuses to acknowledge our
Constitution‘s appeal as a matter of right as evidenced by it enacting and enforcing its own facially
unconstitutional Supreme Court Rule 317 and by refusing to docket or hear this judicial matter in
violation of our Federal Constitution‘s due process right to be heard. With the filing of the Notice of
Appeal the Illinois Supreme Court acquired jurisdiction, and just as the Appellate Court did in this
case, this Court is attempting to convey its will through a non-judicial, ministerial clerk. Our
Constitution forbids such bad acts.
Clerks of the circuit courts are nonjudicial officers of the judicial branch of state
government. Pucinski v. County of Cook, 192 Ill.2d 540, 545, 737 N.E.2d 225, 228 (Ill., 2000);
Kane County v. Carlson, 116 Ill.2d 186, 200, 507 N.E.2d 482, 487 (Ill., 1987); Drury v. County of
McLean, 89 Ill.2d 417, 420, 433 N.E.2d 666, 667 (Ill., 1982)(We hold that under our constitution of
1970 the clerks of the circuit courts in this State *** are nonjudicial members of the judicial branch
of State government.); Ill. Const.1970, Article VI, § 18(b) (―clerks and other non-judicial officers‖).
The Illinois Supreme Court‘s ‗legal advice‘ comes not directly from any Justice but in the
form of a letter (Exhibit 4) from its Clerk stating: ―You are advised that a ‗notice of appeal‘ cannot
be filed to bring a case from the Appellate Court to the Supreme Court.‖ Fascinating. But of course
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just as with any order, judgment or decree emanating from a non-judicial ministerial clerk it is a
legal nullity.
The employees of the Office of the Clerk simply fill clerical positions. see, Keim v. U.S., 177
U.S. 290, 293, 20 S.Ct. 574, 575 (U.S., 1900).
The law is clear that when one acts upon the advice of a deputy clerk, he does so at his
own peril. Libert v. Turzynski, 129 Ill.App.2d 146, 152, 262 N.E.2d 741, 743 (1 Dist., 1970), citing
Bernier v. Schaefer, 11 Ill.2d 525, 530, 144 N.E.2d 577, 579 (Ill., 1957) (It is no part of a deputy
clerk's task to give litigants legal advice.)
This court has jurisdiction on direct appeal of all cases involving a substantial constitutional
question. People v. McGhee, 35 Ill.2d 302, 303, 220 N.E.2d 205, 206 (Ill., 1966); Ill. Const.1970,
art. VI, § 4(c). (Entitled: ―Supreme Court—Jurisdiction.‖); Illinois Appellate Court Act 705 ILCS
25/8.2 (West 2014).
[t]his court has repeatedly stressed that a hearing is required whenever the petitioner
makes a substantial showing of a violation of constitutional rights. People v. Coleman, 183 Ill.2d
366, 381, 701 N.E.2d 1063, 1072 (Ill., 1998) (Citations omitted.)
I relish the predictable logic of the law. I realized the first time that I received an unsigned
‗order‘ in about 2002 created by a Clerk appointed for life by the Judges of the same Appellate
Court, that it was not within a clerk‘s power to render judicial orders because a clerk is a not a
judicial officer. Earlier this year I immediately observed that the Appellate Court Act and Rule 317
unconstitutionally interfered with a constitutional appeal as a matter of right. That is why in my filed
Notice of Appeal (Exhibit 3) I specifically appealed pursuant to the unconstitutional Illinois Appellate
Court Act. The Justices of our Illinois Supreme Court are now proffering that its rules take
precedence over an appeal as a matter of constitutional right. Fascinating.
Now the constitutionality of the Rule, the Act, and the Appellate Court Clerk‘s illegal acts
are all at legal issue in the Illinois Supreme Court that currently has jurisdiction pursuant to the
Notice of Appeal filed as a matter of constitutional right.
14

We have no more right to decline the exercise of jurisdiction which is given, than to usurp
that which is not given. The one or the other would be treason to the Constitution. Ex parte Young,
209 U.S. 123, 142-143, 28 S.Ct. 441, 447 (U.S., 1908).
I now have been directly legally injured. I have legal standing, and justiciable issues have
been presented to the Illinois Supreme Court with jurisdiction transferred to it from the Appellate
Court pursuant to a Notice of Appeal filed as a matter of constitutional right.
The good news is that I have had the absolute pleasure of doing the Justices legal
research already. The bad news is the King has moved itself into Checkmate. Just as pure logic
dictates our constitutions and laws along with a sound and uniform body of uncontroversial legal
precedent state that: 1) A clerk does not have judicial power, and 2) Any Act or Rule that interferes
with a constitutional right is void ab initio.
My legal advice in response to the Supreme Court‘s unsolicited and unsupported ‗legal
advice‘ to me: Start your temerarious legal research with Miranda and never forget that you swore
in your Oath of Office to uphold the Constitutions and Laws of Illinois and the United States. That is
your fulltime duty.
Where rights secured by the Constitution are involved, there can be no rule making or
legislation which would abrogate them. Miranda v. Arizona, 384 U.S. 436, 491, 86 S.Ct. 1602,
1636, 10 A.L.R.3d 974 (U.S., 1966).
Only last year this Court in Blair once again affirmed the applicability our U.S. Supreme
Court‘s Norton rule: The void ab initio doctrine is based on the theory that " ‗An unconstitutional act
is not a law; it confers no rights; it imposes no duties; it affords no protection; it creates no office; it
is, in legal contemplation, as inoperative as though it had never been passed.' " People v. Blair,
2013 IL 114122, ¶ 28, 986 N.E.2d 75, 81 (Ill., 2013), quoting Perlstein v. Wolk, 218 Ill.2d 448, 454,
844 N.E.2d 923, 926 (Ill., 2006), in turn quoting Norton v. Shelby County, 118 U.S. 425, 442, 6
S.Ct. 1121, 30 L.Ed. 178 (U.S., 1886); People v. Schraeberg, 347 Ill. 392, 394, 179 N.E. 829, 830
(Ill., 1932); City of Ottawa v. Hulse, 332 Ill. 286, 293, 163 N.E. 685, 688 (Ill., 1928); Chicago,
Wilmington & Vermilion Coal Co. v. People, 214 Ill. 421, 454, 73 N.E. 770, 780 (Ill., 1905).
15

[a]n unconstitutional act is not a law, and can neither confer a right or immunity nor operate
to supersede any existing valid law. Chicago, I. & L.R. Co. v. Hackett, 228 U.S. 559, 566, 33 S.Ct.
581, 585 (U.S., 1913), citing Norton v. Shelby County, 118 U. S. 425, 442, 6 S.Ct. 1121, 1125, 30
L.Ed. 178, 186 (U.S., 1886); Ex parte Siebold, 100 U. S. 371, 376, 25 L.Ed. 717, 719 (U.S., 1879).
The validity of a rule adopted by this court should be tested by the same standards as are
applicable to a statute. Yellow Cab Co. v. Jones, 108 Ill.2d 330, 338, 483 N.E.2d 1278, 1282 (Ill.,
1985).
[pursuant to the U.S. Supreme Court‘s Norton rule, supra] an unconstitutional statute is
void ab initio, i.e., void ―from the beginning.‖ People v. Blair, 2013 IL 114122, ¶ 28, 986 N.E.2d 75,
81 (Ill., 2013).
[a] law repugnant to the Constitution ―is void, and is as no law,‖ Reynoldsville Casket Co.
v. Hyde, 514 U.S. 749, 760, 115 S.Ct. 1745, 1752 (U.S., 1995) (concurring opinion), quoting Ex
parte Siebold, 100 U.S. 371, 376, 25 L.Ed. 717 (U.S., 1879); Marbury v. Madison, 5 U.S. 137, 180,
2 L.Ed. 60 (U.S., 1803).
Unlike the Miranda right however, this Court does not have the right to remain silent, in fact
each Justice of our Illinois Supreme Court has a fulltime duty. The Justices of our Supreme Court
have sworn upon oath to uphold and enforce our constitutions and laws.
―the judicial branch may, indeed must, intervene in matters generally reserved to the other
branches of state government when an action of the executive or legislative branches offends the
Illinois or United States Constitutions.‖ In re Adoption of L.T.M., 214 Ill.2d 60, 71, 824 N.E.2d 221,
228 (Ill., 2005), quoting In re Adoption of K.L.P., 198 Ill.2d 448, 458, 763 N.E.2d 741, 747 (Ill.,
2002).
It is the duty of the judiciary to construe the Constitution and determine whether its
provisions have been disregarded by the actions of any of the branches of government. Rock v.
Thompson, 85 Ill.2d 410, 418, 426 N.E.2d 891, 896 (Ill., 1981), citing People ex rel. Harrod v.
Illinois Courts Com., 69 Ill.2d 445, 458, 372 N.E.2d 53, 59 (Ill., 1977), see also Powell v.
McCormack, 395 U.S. 486, 506, 89 S.Ct. 1944, 1956, 23 L.Ed.2d 491, 508 (U.S., 1969).
16

A void act [or rule] can afford no protection to the officers who execute it. See, Osborn v.
Bank of U.S., 22 U.S. 738, 868 (U.S., 1824).
Our Illinois Constitution of 1970 is the supreme law of Illinois. Our Illinois Constitution in
Article VI, § 4(c) specifically states: ―Appeals from the Appellate Court to the Supreme Court are a
matter of right if a question under the Constitution of the United States or of this State arises for the
first time in and as a result of the action of the Appellate Court‖. No one, without violating S. Ct.
Rule 137 or their Oath of Office, can attempt to support the legal position that a non-judicial
ministerial clerk can hear legal matters or render judicial orders. (Exhibits 1 and 2)
An order void upon its face and requiring only an inspection of the record to demonstrate its
invalidity is a mere nullity, in legal effect no order at all, conferring no right and affording no
justification. See, Herb v. Pitcairn, 384 Ill. 237, 241, 51 N.E.2d 277, 280 (Ill., 1943) citing, Voorhees
v. Jackson ex dem. Bank of United States, 10 Pet. 449, 475, 35 U.S. 449, 477, 9 L.Ed. 490, 501
(U.S., 1836).
[i]t is well settled that ―[a] judgment, order or decree entered by a court *** which lacks the
inherent power to make or enter the particular order involved, is void, and may be attacked at any
time or in any court, either directly or collaterally.‖ Sarkissian v. Chicago Bd. of Educ., 201 Ill.2d 95,
103, 776 N.E.2d 195, 201 (Ill., 2002), quoting Barnard v. Michael, 392 Ill. 130, 135, 63 N.E.2d 858,
861-62 (Ill., 1945). See also City of Chicago v. Roman, 184 Ill.2d 504, 510, 705 N.E.2d 81, 85 (Ill.,
1998); People v. Wade, 116 Ill.2d 1, 5, 506 N.E.2d 954, 955 (Ill., 1987); R.W. Sawant & Co. v.
Allied Programs Corp., 111 Ill.2d 304, 309, 489 N.E.2d 1360, 1363 (Ill., 1986); City of Chicago v.
Fair Employment Practices Com., 65 Ill.2d 108, 112, 357 N.E.2d 1154, 1155 (Ill., 1976); People ex
rel. Nordlund v. Association of the Winnebago Home for the Aged, 40 Ill.2d 91, 95, 237 N.E.2d 533,
536 (Ill., 1968); Buford v. Chief, Park District Police, 18 Ill.2d 265, 271, 164 N.E.2d 57, 60 (Ill.,
1960); Thayer v. Village of Downers Grove, 369 Ill. 334, 339, 16 N.E.2d 717, 719 (Ill., 1938).
The Act and the Rule interfere with the well settled due process right to be heard to attack
a void order at any time or in any court.
17

It is also well settled that a void judgment, order or decree may be reviewed by appeal or
writ of error. People ex rel. Thaxton v. Coal Belt Electric Railway Co., 311 Ill. 29, 142 N.E. 495;
People v. Evans, 262 Ill. 235, 104 N.E. 646; Hunter v. Hunter, 100 Ill, 519; Goodsell v. Boynton, 1
Scam. 555. A judgment, order or decree of a court that lacked jurisdiction or one that is void for any
other reason will be reversed by this court whenever the same is brought before us by any means
possible in the particular case. Moffat Coal Co. v. Industrial Commission, 397 Ill. 196, 201, 73
N.E.2d 423, 426 (Ill., 1947).
This Court in Moffat recognized the well settled principle of law that a void judgment, order
or decree may be attacked at any time or in any court, either directly or collaterally and therefore
‗will be reversed by this [Supreme] court whenever the same is brought before us by any means
possible in the particular case.‘ That is the procedural due process of law required. An appeal as a
matter of right to the Illinois Supreme Court as granted by our Illinois Constitution of 1970 in Article
VI, § 4(c) includes the due process right to be heard ‗by any means possible‘ and, to attack a void
order ‗at any time‘.
Procedural due process rights are triggered when fundamental right is being denied. East
St. Louis Federation of Teachers, Local 1220 v. E. St. Louis School Dist., 178 Ill.2d 399, 422, 687
N.E.2d 1050, 1063 (Ill., 1997), citing People v. R.G., 131 Ill.2d 328, 342, 546 N.E.2d 533, 540 (Ill.,
1989), Tiller v. Klincar, 138 Ill.2d 1, 13-14, 561 N.E.2d 576, 581 (Ill., 1990), Cleveland Board of
Education v. Loudermill, 470 U.S. 532, 541, 105 S.Ct. 1487, 1493, 84 L.Ed.2d 494, 503 (U.S.,
1985).
To punish a person because he has done what the law plainly allows him to do is a due
process violation ―of the most basic sort.‖ Bordenkircher v. Hayes, 434 U.S. 357, 363, 98 S.Ct. 663,
668, 54 L.Ed.2d 604 (U.S., 1978). In a series of cases beginning with North Carolina v. Pearce and
culminating in Bordenkircher v. Hayes, the Court has recognized this basic—and itself
uncontroversial—principle. For while an individual certainly may be penalized for violating the law,
he just as certainly may not be punished for exercising a protected statutory or constitutional right.
U. S. v. Goodwin, 457 U.S. 368, 372, 102 S.Ct. 2485, 2488 (U.S., 1982).
18

Supreme Court Rule 317 and Illinois Appellate Court Act (705 ILCS 25/8.2) are facially
unconstitutional as interfering with an appeal as a matter of constitutional right and the
constitutional right to transfer jurisdiction and be heard at the Illinois Supreme Court as expressly
granted by our Illinois Constitution in Article VI, § 4(c) and are a corresponding violation of the U.S.
Constitution‘s Fourteenth Amendment due process right to be heard and are therefore void and
present no law at all.
Federal right cannot be defeated by the forms of local practice. Brown v. Western Ry. of
Ala., 338 U.S. 294, 296, 70 S.Ct. 105, 106 (U.S., 1949).
The opportunity to be heard is an essential requisite of due process of law in judicial
proceedings. Richards v. Jefferson County, Ala., 517 U.S. 793, 797, 116 S.Ct. 1761, 1765
(U.S.,1996), citing Windsor v. McVeigh, 93 U.S. 274, 277, 23 L.Ed. 914 (U.S., 1876); Louisville &
Nashville R.R. Co. v. Schmidt, 177 U.S. 230, 236, 20 S.Ct. 620, 622, 44 L.Ed. 747 (U.S., 1900);
Simon v. Craft, 182 U.S. 427, 436, 21 S.Ct. 836, 839, 45 L.Ed. 1165 (U.S., 1901).
A denial to a party of the benefit of a hearing would be in effect to deny that he is entitled to
hearing at all, and a sham and deceptive proceeding altogether. See, Windsor v. McVeigh, 93 U.S.
274, 277-278, 23 L.Ed. 914 (U.S., 1876).
Under our Constitution no court, state or federal, may serve as an accomplice in the willful
transgression of ‗the Laws of the United States,‘ laws by which ‗the Judges in every State (are)
bound. ...‘ ‖‘‖ U.S. v. Peltier 422 U.S. 531, 537, 95 S.Ct. 2313, 2317 (1975), quoting Lee v. State of
Florida, 392 U.S. 378, 385-86, 888 S.Ct. 2096, 2101, 20 L.Ed.2d 1166 (U.S., 1968) (footnotes
omitted); Art. VI, cl. 2, U.S.Const.
‗The general doctrine of Osborn v. Bank of United States, that the circuit courts of the
United States will restrain a state officer from executing an unconstitutional statute of the state,
when to execute it would violate rights and privileges of the complainant which had been
guaranteed by the Constitution, and would work irreparable damage and injury to him, has never
been departed from.‘ The same principle is decided in Scott v. Donald, 165 U. S. 58–67, 41 L.Ed.
632, 633, 17 Sup. Ct. Rep. 265. And see Missouri, K. & T. R. Co. v. Missouri R. & Warehouse
19

Comrs. (Missouri, K. & T. R. Co. v. Hickman) 183 U. S. 53, 46 L.Ed. 78, 22 Sup. Ct. Rep. 18. Ex
parte Young, 209 U.S. 123, 152, 28 S.Ct. 441, 451 (U.S., 1908), quoting Pennoyer v.
McConnaughy, 140 U.S. 1, 9, 11 S.Ct. 699, 35 L.Ed. 363, 365 (U.S., 1891), in turn citing Osborn v.
Bank of United States, 9 Wheat. 738, 846, 857, 6 L.Ed. 204 (U.S., 1824).
Check is a foreseeably avoidable predicament in Chess in which those who fail to
comprehend or apply the rules judiciously place their King in a position that is checked by
operation of law and the only move remaining to avoid the inevitable Checkmate is to follow the
clear path of the law to avoid the labyrinth of perplexities that arise from the right to attack void
orders, acts, and rules at any time, in any court, eternally. That right of course is unlimited in scope
and includes a federal injunction and a mandamus proceeding before the U.S. Supreme Court.
It [Illinois Courts] may not, however, shut its doors entirely to federal constitutional claims.
The supremacy clause of the United States Constitution (U.S. Const., art. VI, cl. 2) requires state
courts to enforce federal law and state court judges to be bound by it. As the United States
Supreme Court held more than a century ago, ―Upon the State Courts, equally with the Courts of
the Union, rests the obligation to guard, enforce and protect every right granted or secured by the
Constitution of the United States and the laws made in pursuance thereof, whenever those rights
are involved in any suit or proceeding before them; for, the Judges of the State Courts are required
to take an oath to support that Constitution, and they are bound by it and the laws of the United
States made in pursuance thereof and all treaties made under their authority, as the supreme law
of the land, ‗anything in the Constitution or laws of any State to the contrary notwithstanding.‘ ‖
People v. Lawton, 212 Ill.2d 285, 301, 818 N.E.2d 326, 336 (Ill., 2004), quoting Robb v. Connolly,
111 U.S. 624, 637, 4 S.Ct. 544, 551, 28 L.Ed. 542, 546 (U.S., 1884); McKesson Corp. v. Division of
Alcoholic Beverages and Tobacco, Dept., 496 U.S. 18, 31, 110 S.Ct. 2238, 2247 (U.S., 1990); Ex
parte Young, 209 U.S. 123, 176-77, 28 S.Ct. 441, 461 (U.S., 1908); Missouri Pac. Ry. Co. v.
Fitzgerald, 160 U.S. 556, 583-84, 16 S.Ct. 389, 396 (U.S., 1896) “If they fail therein, and
withhold or deny rights, privileges, or immunities secured by the Constitution and laws of
the United States, the party aggrieved may bring the case from the highest court of the State
in which the question could be decided to this court for final and conclusive determination.”
20

(Emphasis added.) McKesson Corp. v. Division of Alcoholic Beverages and Tobacco, Dept., 496
U.S. 18, 31, 110 S.Ct. 2238, 2247, 110 L.Ed. 17 (U.S., 1990), quoting Robb v. Connolly, 111 U.S.
624, 637, 4 S.Ct. 544, 551, 28 L.Ed. 542 (U.S., 1884); Ex parte Young, 209 U.S. 123, 177, 28 S.Ct.
441, 461, 52 L.Ed. 714 (U.S., 1908); Gibson v. State of Mississippi, 162 U.S. 565, 586, 16 S.Ct.
904, 908, 40 L.Ed. 1075 (U.S., 1896); Missouri Pac. Ry. Co. v. Fitzgerald, 160 U.S. 556, 584, 16
S.Ct. 389, 396-97, 40 L.Ed. 536 (U.S., 1896); Wood v. Brush, 140 U.S. 278, 286, 11 S.Ct. 738,
741, 35 L.Ed. 505 (U.S., 1891).
―Under these circumstances, the language of Chief Justice Marshall in Cohen v. Virginia, 6
Wheat. 264–404, 5 L.Ed. 257–291, is most apposite. In that case he said: ‗It is most true that this
court will not take jurisdiction if it should not; but it is equally true that it must take jurisdiction if it
should. The judiciary cannot, as the legislature may, avoid a measure because it approaches the
confines of the Constitution. We cannot pass it by because it is doubtful. With whatever doubts,
with whatever difficulties, a case may be attended, we must decide it, if it be brought before us. We
have no more right to decline the exercise of jurisdiction which is given, than to usurp that which is
not given. The one or the other would be treason to the Constitution. Questions may occur which
we would gladly avoid, but we cannot avoid them. All we can do is to exercise our best judgment,
and conscientiously to perform our duty.‘ ‖ Ex parte Young, 209 U.S. 123, 142-143, 28 S.Ct. 441,
447 (U.S., 1908); U. S. v. Will, 449 U.S. 200, 216, 101 S.Ct. 471, 481 (U.S., 1980).
The Illinois Supreme Court acquired jurisdiction contemporaneously with the filing of the
Notice of Appeal in case 2-12-0688. This Court has a duty to docket this case, assign a case
number, hear this case in a judicial manner, and declare Illinois Supreme Court Rule 317 and
Illinois Appellate Court Act (705 ILCS 25/8.2) unconstitutional.
Respectfully submitted
______________________________
Christopher A. Briggs
809 N. County Street
Waukegan, Illinois 60085
847-687-5590
June 4, 2014 [email protected]
21

Case No. 2014 IL ________
IN THE SUPREME COURT OF ILLINOIS

People of the State of Illinois, ) Appeal from the Appellate Court, Second
Appellee - Plaintiff ) Judicial District, Case No. 2-12-0688
)
) Circuit Court of the Nineteenth Judicial
v. ) Circuit, Lake County, Illinois
) Case No. 07 CM 8549
)
Christopher Briggs, ) Honorable Michael Betar, Presiding
Appellant - Defendant ) Trial Judge.




















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