sound basis for further inquiry (Illinois) · Go Syfert
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sound basis for further inquiry in Illinois

32 Illinois opinions name it 2 courts 1995–2026 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 (8)

CaseFollowedCited
People v. Pecorarogreen
ill · 1997 · cited in 9 Illinois opinions naming this issue, 2003–2026
2 sentences

2025See Pecoraro, 175 Ill. 2d at 324-25 (“[i] t was entirely reasonable for counsel to focus his strategy on the weaknesses in the State’s case rather than developing a speculative theory”). ¶ 57 Furthermore, in Orange, 168 Ill. 2d at 149 , our supreme court found that “[c]ounsel has only a duty to make reasonable investigations or to make a reasonable decision which makes particular investigations unnecessary.” “Where the circumstances known to counsel at the time of his investigation do not reveal a sound basis for further inquiry in a particular area, it is not ineffective for the attorney to f

2021If “circumstances known to counsel at the time of his investigation do not reveal a sound basis for further inquiry in a particular area, it is not ineffective for the attorney to forgo additional investigation.” People v. Pecoraro, 175 Ill. 2d 294, 324 (1997). ¶ 33 In this case, trial counsel had a sound basis for not further investigating or presenting an uncorroborated alibi defense from defendant’s grandfather.

59
People v. Holmangreen
ill · 1995 · cited in 6 Illinois opinions naming this issue, 1995–2022
2 sentences

2022“Where the circumstances known to counsel at the time of his investigation do not reveal a sound basis for further inquiry in a particular area, it is not ineffective for the attorney to forgo additional investigation.” People v. Holman, 164 Ill. 2d 356, 371 (1995).

1997"Where the circumstances known to counsel at the time of his investigation do not reveal a sound basis for further inquiry in a particular area, it is not ineffective for the attorney to forgo additional investigation. [Citation.]” People v. Holman, 164 Ill. 2d 356, 371 (1995).

56
People v. Orangegreen
ill · 1995 · cited in 15 Illinois opinions naming this issue, 1997–2025
2 sentences

2025See Pecoraro, 175 Ill. 2d at 324-25 (“[i] t was entirely reasonable for counsel to focus his strategy on the weaknesses in the State’s case rather than developing a speculative theory”). ¶ 57 Furthermore, in Orange, 168 Ill. 2d at 149 , our supreme court found that “[c]ounsel has only a duty to make reasonable investigations or to make a reasonable decision which makes particular investigations unnecessary.” “Where the circumstances known to counsel at the time of his investigation do not reveal a sound basis for further inquiry in a particular area, it is not ineffective for the attorney to f

2025“However, ‘the reasonableness of a decision to investigate is assessed applying a heavy measure of deference to counsel’s judgment.’ [Citation.] An attorney who forgoes further investigation is not ineffective ‘[w]here the circumstances known to counsel at the time of his investigation do not reveal the sound basis for further inquiry in a particular area.’ [Citation.]” Griffin, 2024 IL App (1st) 191101-C, ¶ 39 (quoting People v. Orange, 168 Ill. 2d 138, 149-50 (1995)). ¶ 54 Defendant argues that it was unreasonable for the trial attorney to choose not to present Taylor as a witness without fi

415
People v. Madejred
ill · 1997 · cited in 1 Illinois opinions naming this issue, 2024–2024
1 sentence

2024Defendant adds that defense counsel could have sought reconsideration of the ruling on the motion to suppress statements based on newly discovered evidence at any time prior to the issuance of a final judgment on August 19, 2009. ¶ 74 An attorney must conduct a reasonable investigation of the facts underlying a case; a decision to forgo investigation of a possible claim or defense must be based on an “informed judgment,” in that “the facts and circumstances do not reveal a sound basis for further inquiry into a particular area.” People v. Madej, 177 Ill. 2d 116, 135-36 (1997).

11
People v. Elliottgreen
illappct · 2022 · cited in 1 Illinois opinions naming this issue, 2023–2023
1 sentence

2023See Hodges, 234 Ill. 2d at 17 . ¶ 60 Nor can we conclude that counsel’s performance was arguably deficient in that he failed to investigate such an expert, given that, “ ‘[w]here circumstances known to counsel at the time do not reveal a sound basis for further inquiry in a particular area, it is not ineffective for the attorney to forgo additional investigation.’ ” People v. Elliott, 2022 IL App (1st) 192294, ¶ 39 (quoting People v. Williams, 2017 IL App (1st) 152021, ¶ 38 ).

11
People v. Hodgesgreen
ill · 2009 · cited in 1 Illinois opinions naming this issue, 2023–2023
1 sentence

2023See Hodges, 234 Ill. 2d at 17 . ¶ 60 Nor can we conclude that counsel’s performance was arguably deficient in that he failed to investigate such an expert, given that, “ ‘[w]here circumstances known to counsel at the time do not reveal a sound basis for further inquiry in a particular area, it is not ineffective for the attorney to forgo additional investigation.’ ” People v. Elliott, 2022 IL App (1st) 192294, ¶ 39 (quoting People v. Williams, 2017 IL App (1st) 152021, ¶ 38 ).

11
People v. Hendersongreen
ill · 1996 · cited in 1 Illinois opinions naming this issue, 2021–2021
1 sentence

2021See People v. Henderson, 171 Ill. 2d 124, 143 (1996) (“Defendant’s trial counsel therefore cannot be faulted for failing to present a medical record which did not exist at the time of the [suppression] hearing.”); People v. Williams, 2017 IL App (1st) 152021, ¶ 38 (“Where circumstances known to counsel at the time do not reveal a sound basis for further inquiry in a particular area, it is not ineffective for the attorney to forgo additional investigation.”).

11
People v. Hintongreen
illappct · 1998 · cited in 1 Illinois opinions naming this issue, 2007–2007
2 sentences

2007Hinton, 302 Ill.App.3d at 619-24 , 236 Ill.Dec. 143 , 706 N.E.2d at 1021-24 (holding that defendant had not established there was a sound basis for further inquiry where there was no evidence of injury other than defendant's testimony and his allegation that counsel failed to introduce his bloody shirt); Orange, 168 Ill.2d at 150 , 213 Ill.

2007Hinton, 302 Ill.App.3d at 619-24 , 236 Ill.Dec. 143 , 706 N.E.2d at 1021-24 (holding that defendant had not established there was a sound basis for further inquiry where there was no evidence of injury other than defendant's testimony and his allegation that counsel failed to introduce his bloody shirt); Orange, 168 Ill.2d at 150 , 213 Ill.

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 (3)

CaseCitedYears
People v. Simmons green
illappct · 2020
1 sentence

2024Nevertheless, failing to investigate known witnesses “can indicate -7- incompetence when their testimony could be exonerating.” People v. Simmons, 2020 IL App (1st) 170650, ¶ 42 .

12024–2024
People v. Tenner green
ill · 1997
1 sentence

2022In People v. Tenner, 175 Ill. 2d 372, 379-81 (1997), the defendant contended that his trial counsel was ineffective for failing to order a mental evaluation prior to trial in order to support an insanity defense.

12022–2022
People v. Eddmonds green
ill · 1991
1 sentence

1995(People v. Eddmonds (1991), 143 Ill. 2d 501, 532 .) We cannot say that attorney Bjekich was incompetent because he failed to recognize that defendant might be suffering from a mental disability, where there were no external indicia that would have prompted the attorney to suspect that the defendant was so afflicted.

11995–1995

Statutes the citing opinions construe

IL § 725 ILCS 5/122-1 (16) IL § 725 ILCS 5/122-2.1 (9) IL § 725 ILCS 5/122-2 (6) IL § 725 ILCS 5/122-5 (4) IL § 725 ILCS 5/122-6 (4) IL § 730 ILCS 5/5-8-1 (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.

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