validity of a jury waiver (Illinois) · Go Syfert
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validity of a jury waiver in Illinois

36 Illinois opinions name it 1 courts 1972–2026 13 in the last five years

The cases below were cited by Illinois courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (6)

CaseFollowedCited
People v. Freygreen
ill · 1984 · cited in 3 Illinois opinions naming this issue, 2005–2022
2 sentences

2022See People v. Frey, 103 Ill. 2d 327, 330 (1984) (upholding the validity of a jury waiver where defendant’s counsel, in defendant’s presence, advised the court that defendant elected to waive his right to a jury trial, and defendant made no objection to the assertion).

2005In re R.A.B., 197 Ill. 2d at 364 ; People v. Frey, 103 Ill. 2d 327, 332 (1984).

33
In Re RABgreen
ill · 2001 · cited in 8 Illinois opinions naming this issue, 2005–2017
2 sentences

2017The validity of a jury waiver cannot rest on any precise formula, but, rather, “depends on the facts and circumstances of each particular case. [Citation.] A jury waiver may be valid if it is made by defense counsel in the defendant’s presence and the defendant does not object.” In re R.A.B., 197 Ill. 2d 358, 364 (2001). ¶ 24 Here, the record contains no evidence that defendant waived his right to a jury trial either in writing or in open court.

2017The validity of a jury waiver cannot rest on any precise formula, but, rather, “depends on the facts and circumstances of each particular case. [Citation.] A jury waiver may be valid if it is made by defense counsel in the defendant’s presence and the defendant does not object.” In re R.A.B., 197 Ill. 2d 358, 364 (2001). ¶ 24 Here, the record contains no evidence that defendant waived his right to a jury trial either in writing or in open court.

28
People v. Bannistergreen
ill · 2008 · cited in 6 Illinois opinions naming this issue, 2019–2025
2 sentences

2022Bannister, 232 Ill. 2d at 66 . ¶ 39 On appeal, it is the burden of a defendant challenging the validity of a jury waiver to establish that the waiver was not understanding or voluntary.

2020The validity of a jury waiver “depends on the facts and circumstances of each particular case.” People v. Bannister, 232 Ill. 2d 52, 66 (2008).

26
People v. Braceygreen
ill · 2004 · cited in 10 Illinois opinions naming this issue, 2006–2026
2 sentences

2021The validity of a jury waiver “cannot be determined by application of a precise formula, but rather turns on the particular facts and circumstances of each case.” Bracey, 213 Ill. 2d at 269 . ¶ 18 “Generally, a jury waiver is valid if it is made by defense counsel in defendant’s presence in open court, without an objection by defendant.” Id. at 270 .

2021The validity of a jury waiver “cannot be determined by application of a precise formula, but rather turns on the particular facts and circumstances of each case.” Bracey, 213 Ill. 2d at 269 . ¶ 18 “Generally, a jury waiver is valid if it is made by defense counsel in defendant’s presence in open court, without an objection by defendant.” Id. at 270 .

110
People v. Taylorgreen
ill · 1984 · cited in 1 Illinois opinions naming this issue, 2025–2025
1 sentence

2025App. 3d 236, 238 (2006) (“A reviewing court’s determination of the validity of a jury waiver is not subject to a precise formula, but instead depends upon the particular facts and circumstances of each case.”); People v. Taylor, 101 Ill. 2d 508, 520 (1984) (determination of understanding waiver “necessarily depends” on facts and circumstances). ¶ 20 Nonetheless, the court proceedings must adhere to some baseline rules.

11
People v. Hatchergreen
illappct · 2024 · cited in 1 Illinois opinions naming this issue, 2024–2024
1 sentence

2024Id. ¶ 47. ¶ 11 We find the defendant’s emphasis on the trial court’s failure to explain the difference between a jury trial and a bench trial to be unavailing. 1 “While the trial court has a duty to ensure that a defendant’s waiver of his or her right to a jury trial is made expressly and understandingly, the court is not required to provide any particular admonition or information regarding that right.” 1 We strongly encourage the trial court to take the minimal amount of time required to explain to future defendants, on the record, the difference between a jury trial and a bench trial when d

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Illinois. Read the followed side critically anyway.

Also cited on this issue (14)

CaseCitedYears
People v. Parker green
illappct · 2016
2 sentences

2023People v. Parker, 2016 IL App (1st) 141597, ¶ 47 .

2022Parker, 2016 IL App (1st) 141597, ¶ 47 .

22022–2023
People v. Stokes green
illappct · 1996
2 sentences

1998People v. Stokes, 281 Ill.

1998People v. Stokes , 281 Ill.

21998–1998
People v. Buschauer green
illappct · 2025
1 sentence

2025Buschauer, 2025 IL App (1st) 232365, ¶ 40 .

12025–2025
People v. Smith green
ill · 1985
1 sentence

2025The trial court must ensure the defendant’s waiver was made “expressly and understandingly.” Smith, 106 Ill. 2d at 334 .

12025–2025
People v. Reed green
illappct · 2016
1 sentence

2025Id.

12025–2025
People v. Foster green
illappct · 2022
1 sentence

2024Id. ¶ 47. ¶ 11 We find the defendant’s emphasis on the trial court’s failure to explain the difference between a jury trial and a bench trial to be unavailing. 1 “While the trial court has a duty to ensure that a defendant’s waiver of his or her right to a jury trial is made expressly and understandingly, the court is not required to provide any particular admonition or information regarding that right.” 1 We strongly encourage the trial court to take the minimal amount of time required to explain to future defendants, on the record, the difference between a jury trial and a bench trial when d

12024–2024
People v. Harper green
illappct · 2017
1 sentence

2021Bannister, 232 Ill. 2d at 66; Harper, 2017 IL App (4th) 150045, ¶ 31 .

12021–2021
People v. Tucker green
illappct · 1989
1 sentence

2021“Since the accused speaks and acts through his attorney, the trial court is entitled to rely on the defense attorney to execute his professional responsibilities.” People v. Tucker, 183 Ill.

12021–2021
People v. McGee green
illappct · 1994
2 sentences

1996People v. Sandham, 276 Ill.App.3d 86, 88 , 212 Ill.Dec. 518 , 657 N.E.2d 719 (1995); People v. McGee, 268 Ill.App.3d 582, 585 , 206 Ill.Dec. 324 , 645 N.E.2d 329 (1994).

1996People v. Sandham, 276 Ill.App.3d 86, 88 , 212 Ill.Dec. 518 , 657 N.E.2d 719 (1995); People v. McGee, 268 Ill.App.3d 582, 585 , 206 Ill.Dec. 324 , 645 N.E.2d 329 (1994).

11996–1996
People v. Sandham green
illappct · 1995
2 sentences

1996People v. Sandham, 276 Ill.

1996People v. Sandham, 276 Ill.App.3d 86, 88 , 212 Ill.Dec. 518 , 657 N.E.2d 719 (1995); People v. McGee, 268 Ill.App.3d 582, 585 , 206 Ill.Dec. 324 , 645 N.E.2d 329 (1994).

11996–1996
People v. Hall green
illappct · 1991
1 sentence

1993App. 3d 864 , 583 N.E.2d 54 , we recently invoked the plain error rule to review the validity of a jury waiver even though the State argued waiver, because the defendant did not raise the issue in his post-trial motion.

11993–1993
The PEOPLE v. Richardson green
ill · 1965
2 sentences

1977(People v. Richardson (1965), 32 Ill. 2d 497, 499 , 207 N.E.2d 453 .) While the trial court may not perfunctorily discharge its duty to explain the right to a jury trial to an accused, this is not to suggest that an explanation of the ramifications of such waiver is necessary unless there is an indication the accused does not understand his right to a jury trial.

1977(People v. Richardson (1965), 32 Ill. 2d 497, 499 , 207 N.E.2d 453 .) While the trial court may not perfunctorily discharge its duty to explain the right to a jury trial to an accused, this is not to suggest that an explanation of the ramifications of such waiver is necessary unless there is an indication the accused does not understand his right to a jury trial.

11977–1977
People v. Bradley green
illappct · 1970
2 sentences

1972People v. Bradley, 131 Ill.App.2d 91 , 266 N.E.2d 469 .

1972People v. Bradley, 131 Ill.App.2d 91 , 266 N.E.2d 469 .

11972–1972
The People v. Wesley green
ill · 1964
2 sentences

1972(People v. Wesley, 30 Ill.2d 131 , 195 N.E.2d 708 .) However, a lengthy explanation of the consequences of a jury trial is not a prerequisite to the validity of a jury waiver.

1972(People v. Wesley, 30 Ill.2d 131 , 195 N.E.2d 708 .) However, a lengthy explanation of the consequences of a jury trial is not a prerequisite to the validity of a jury waiver.

11972–1972

Statutes the citing opinions construe

IL § 725 ILCS 5/103-6 (13) IL § 725 ILCS 5/115-1 (9) IL § 720 ILCS 5/12-3.2 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

IL 36 (1972–2026) CA 11 (2017–2026) PA 6 (2008–2022) CT 4 (1986–2025) TX 3 (1991–2003) OH 2 (2016–2025) MA 2 (1979–2009) MD 2 (2005–2007)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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