Ameen Salaam v. Illinois, ex. rel. Kimberly Foxx
DueProcess
Whether a court can enter a final judgment without the notice required by the due process clause
QUESTIONS PRESENTED FOR REVIEW 1. When a court has in rem jurisdiction can it enter a final judgment without the notice required by the due process clause. 2. Whether a judgment that is void because the notice necessitated by the due process clause was not provided can become unassailable by the passage of time. The State of Illinois forfeited money in a civil judicial forfeiture proceeding, without notice to claimant Salaam. Denying relief, the Illinois Supreme Court ruled “even if that lack of notice amounted to a due process violation, [it] could not deprive the circuit court of its jurisdiction” to enter a final judgment of forfeiture. People ex rel. Alvarez v. $59, 914, 2022 IL 126927, § 23.