statutory speedy trial violation (Illinois) · Go Syfert
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statutory speedy trial violation in Illinois

30 Illinois opinions name it 2 courts 1994–2026 15 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 (20)

CaseFollowedCited
People v. Cordellgreen
ill · 2006 · cited in 2 Illinois opinions naming this issue, 2021–2025
2 sentences

2025As stated in People v. Cordell, 223 Ill. 2d 380, 390 (2006), “[s]hould a defendant wish to employ section 103-5(a) as a shield against any attempt to place his trial date outside the 120-day period, he is free to do so.

2021People v. Cordell, 223 Ill. 2d 380, 385 (2006).

22
People v. Klinergreen
ill · 1998 · cited in 2 Illinois opinions naming this issue, 2023–2024
2 sentences

2024People v. Kliner, 185 Ill. 2d 81, 114 (1998). “[D]efense counsel’s express agreement to a continuance may be considered an affirmative act contributing to a delay which is attributable to the defendant.” Id.

2024People v. Kliner, 185 Ill. 2d 81, 114 (1998). “[D]efense counsel’s express agreement to a continuance may be considered an affirmative act contributing to a delay which is attributable to the defendant.” Id.

22
People v. Sebbygreen
ill · 2017 · cited in 2 Illinois opinions naming this issue, 2020–2020
2 sentences

2020See id. ¶3 Second, defendant asserts that his appointed trial counsel rendered ineffective assistance by failing to move for a discharge on statutory speedy-trial grounds and by failing to raise the issue in the posttrial motion, thereby causing a forfeiture of the issue.

2020See id. ¶3 Second, defendant asserts that his appointed trial counsel rendered ineffective assistance by failing to move for a discharge on statutory speedy-trial grounds and by failing to raise the issue in the posttrial motion, thereby causing a forfeiture of the issue.

22
People v. Vasquezgreen
illappct · 2000 · cited in 2 Illinois opinions naming this issue, 2000–2000
2 sentences

2000People v. Vasquez, 311 Ill.

2000People v. Vasquez , 311 Ill.

22
People v. Staakegreen
ill · 2017 · cited in 3 Illinois opinions naming this issue, 2022–2024
2 sentences

2022See People v. Staake, 2017 IL 121755, ¶ 33 , 102 N.E.3d 217 (finding it unnecessary in that case to determine whether the appellate court precedent finding a forfeited error involving a statutory speedy-trial violation is reviewable as second- prong plain error should be overruled).

2022See People v. Staake, 2017 IL 121755, ¶ 33 , 102 N.E.3d 217 (finding it unnecessary in that case to determine whether the appellate court precedent finding a forfeited error involving a statutory speedy-trial violation is reviewable as second- prong plain error should be overruled).

13
People v. Pearsongreen
ill · 1981 · cited in 3 Illinois opinions naming this issue, 2012–2024
2 sentences

2024The argument was raised in both People v. Staake, 2017 IL 121755 , and People v. Hartfield, 2022 IL 126729 , but this court found no error occurred in either case and, therefore, did not reach the issue. ¶ 31 This court did discuss section 103-5 in People v. Pearson, 88 Ill. 2d 210 (1981), in the context of whether a speedy trial violation may be raised for the first time in a posttrial motion.

2012Section 114-1(b) of the Code provides that any motions for dismissal based upon a statutory speedy-trial violation, not made in writing prior to trial, “are waived.” 725 ILCS 5/114-1(b) (West 2006); see People v. Pearson, 88 Ill. 2d 210, 218 (1981); People v. Peco, 345 Ill.

13
Strickland v. Washingtongreen
scotus · 1984 · cited in 2 Illinois opinions naming this issue, 2022–2025
2 sentences

2025In addition, it presents an appropriate way to get the statutory speedy trial claim before the circuit court in a postconviction petition. ¶ 33 The constitutional issue of whether appellate counsel was ineffective has not been addressed by this court, and as previously stated, we will address Cotledge’s ineffective assistance of appellate counsel claims. ¶ 34 We review claims of ineffective assistance of counsel under the standard set forth in Strickland v. Washington, 466 U.S. 668 (1984).

2022Strickland v. Washington, 466 U.S. 668, 687 (1984). ¶ 41 First, the defendant argues that his counsel was ineffective for failing to move for dismissal on the basis of a statutory speedy-trial violation.

12
People v. Cranegreen
ill · 2001 · cited in 1 Illinois opinions naming this issue, 2026–2026
1 sentence

2026Kaczmarek, 207 Ill. 2d at 295 (citing People v. Crane, 195 Ill. 2d 42, 52 (2001)). 19 ¶ 47 Section 103-5 of the Code provides the basis for a statutory speedy trial violation. 725 ILCS 5/103-5 (West 2022).

11
People v. Castillogreen
illappct · 2007 · cited in 1 Illinois opinions naming this issue, 2025–2025
1 sentence

2025Defendant could have raised the statutory speedy trial violation in a written or oral motion for new trial (see People v. Castillo, 372 Ill.

11
People v. Princegreen
illappct · 1993 · cited in 1 Illinois opinions naming this issue, 2025–2025
1 sentence

2025App. 3d 11, 15-16 (2007); People v. Prince, 242 Ill.

11
People v. Williamsgreen
ill · 2024 · cited in 1 Illinois opinions naming this issue, 2025–2025
1 sentence

2025People v. Williams, 2024 IL 127304, ¶ 22 (counsel is not ineffective for failing to raise a meritless argument).

11
People v. Westgreen
ill · 1999 · cited in 1 Illinois opinions naming this issue, 2025–2025
1 sentence

2025People v. West, 187 Ill. 2d 418, 432 (1999). ¶ 46 A statutory speedy-trial claim under section 103-5(a) must be asserted before trial through a motion to dismiss. 725 ILCS 5/114-1(a)(1) (West 2022).

11
People v. McKinneygreen
illappct · 2011 · cited in 1 Illinois opinions naming this issue, 2022–2022
1 sentence

2022See People v. Smith, 2016 IL App (3d) 140235, ¶¶ 10, 21 , 55 N.E.3d 719 (citing People v. McKinney, 2011 IL App (1st) 100317 , 962 N.E.2d 1084 , and simply restating what constitutes - 19 - second-prong plain error); McKinney, 2011 IL App (1st) 100317, ¶¶ 29, 31 (finding no error and simply citing People v. Gay, 376 Ill.

11
People v. McKinneygreen
illappct · 2011 · cited in 1 Illinois opinions naming this issue, 2022–2022
2 sentences

2022See People v. Smith, 2016 IL App (3d) 140235, ¶¶ 10, 21 , 55 N.E.3d 719 (citing People v. McKinney, 2011 IL App (1st) 100317 , 962 N.E.2d 1084 , and simply restating what constitutes - 19 - second-prong plain error); McKinney, 2011 IL App (1st) 100317, ¶¶ 29, 31 (finding no error and simply citing People v. Gay, 376 Ill.

2022See People v. Smith, 2016 IL App (3d) 140235, ¶¶ 10, 21 , 55 N.E.3d 719 (citing People v. McKinney, 2011 IL App (1st) 100317 , 962 N.E.2d 1084 , and simply restating what constitutes - 19 - second-prong plain error); McKinney, 2011 IL App (1st) 100317, ¶¶ 29, 31 (finding no error and simply citing People v. Gay, 376 Ill.

11
People v. Smithgreen
illappct · 2016 · cited in 1 Illinois opinions naming this issue, 2022–2022
2 sentences

2022S. Ct. R. 615(a); People v. Smith, 2016 IL App (3d) 140235, ¶ 10 (noting that where a defendant failed to properly preserve a speedy-trial matter for review, it is reviewable for plain error because it implicates fundamental constitutional concerns); McKinney, 2011 IL Ap (1st) 100317, ¶ 29.” Defendant did not assert plain error in his opening brief. ¶ 47 Our supreme court recently addressed a statutory speedy-trial claim and noted the following: “The people of Illinois possess both constitutional and statutory rights to a speedy trial.

2022See People v. Smith, 2016 IL App (3d) 140235, ¶¶ 10, 21 , 55 N.E.3d 719 (citing People v. McKinney, 2011 IL App (1st) 100317 , 962 N.E.2d 1084 , and simply restating what constitutes - 19 - second-prong plain error); McKinney, 2011 IL App (1st) 100317, ¶¶ 29, 31 (finding no error and simply citing People v. Gay, 376 Ill.

11
People v. Pattersongreen
illappct · 2009 · cited in 1 Illinois opinions naming this issue, 2021–2021
1 sentence

2021People v. Patterson, 392 Ill.

11
People v. Decaturgreen
illappct · 1989 · cited in 1 Illinois opinions naming this issue, 2018–2018
2 sentences

2018See People v. Decatur , 191 Ill.

2018See People v. Decatur , 191 Ill.

11
People v. Pecogreen
illappct · 2004 · cited in 1 Illinois opinions naming this issue, 2012–2012
1 sentence

2012Section 114-1(b) of the Code provides that any motions for dismissal based upon a statutory speedy-trial violation, not made in writing prior to trial, “are waived.” 725 ILCS 5/114-1(b) (West 2006); see People v. Pearson, 88 Ill. 2d 210, 218 (1981); People v. Peco, 345 Ill.

11
People v. Bivensgreen
illappct · 1976 · cited in 1 Illinois opinions naming this issue, 1994–1994
11
People v. Thomasgreen
illappct · 1986 · cited in 1 Illinois opinions naming this issue, 1994–1994
1 sentence

1994App. 3d 79 ; see also People v. Thomas (1986), 149 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 (11)

CaseCitedYears
People v. Staten green
ill · 1994
2 sentences

2008When a statutory speedy trial violation is alleged, “ ‘the statute operates to prevent the constitutional issue from arising except in cases involving prolonged delay, or novel issues.’ ” Staten, 159 Ill. 2d at 426 , quoting People v. Stuckey, 34 Ill. 2d 521, 523 , 216 N.E.2d 785 (1966).

2008When a statutory speedy-trial violation is alleged, "the statute operates to prevent the constitutional issue from arising except in cases involving prolonged delay, or novel issues." Staten, 159 Ill.2d at 426 , 203 Ill.Dec. 230 , 639 N.E.2d 550 (quoting People v. Stuckey, 34 Ill.2d 521, 523 , 216 N.E.2d 785 (1966)).

81997–2023
The PEOPLE v. Stuckey green
ill · 1966
2 sentences

2008When a statutory speedy trial violation is alleged, “ ‘the statute operates to prevent the constitutional issue from arising except in cases involving prolonged delay, or novel issues.’ ” Staten, 159 Ill. 2d at 426 , quoting People v. Stuckey, 34 Ill. 2d 521, 523 , 216 N.E.2d 785 (1966).

2008When a statutory speedy trial violation is alleged, “ ‘the statute operates to prevent the constitutional issue from arising except in cases involving prolonged delay, or novel issues.’ ” Staten, 159 Ill. 2d at 426 , quoting People v. Stuckey, 34 Ill. 2d 521, 523 , 216 N.E.2d 785 (1966).

31994–2008
People v. Hartfield green
ill · 2022
2 sentences

2024The argument was raised in both People v. Staake, 2017 IL 121755 , and People v. Hartfield, 2022 IL 126729 , but this court found no error occurred in either case and, therefore, did not reach the issue. ¶ 31 This court did discuss section 103-5 in People v. Pearson, 88 Ill. 2d 210 (1981), in the context of whether a speedy trial violation may be raised for the first time in a posttrial motion.

2024The argument was raised in both People v. Staake, 2017 IL 121755 , and People v. Hartfield, 2022 IL 126729 , but this court found no error occurred in either case and, therefore, did not reach the issue. -6- ¶ 31 This court did discuss section 103-5 in People v. Pearson, 88 Ill. 2d 210 (1981), in the context of whether a speedy trial violation may be raised for the first time in a posttrial motion.

22024–2024
People v. Kaczmarek green
ill · 2003
1 sentence

2026Kaczmarek, 207 Ill. 2d at 295 (citing People v. Crane, 195 Ill. 2d 42, 52 (2001)). 19 ¶ 47 Section 103-5 of the Code provides the basis for a statutory speedy trial violation. 725 ILCS 5/103-5 (West 2022).

12026–2026
People v. Battles green
illappct · 2000
1 sentence

2025Because defendant cannot establish either deficient performance or prejudice under Strickland, his claim of ineffective assistance of counsel fails. ¶ 48 Additionally, because the claim is predicated on alleged failures to preserve the statutory speedy-trial claim, we need not evaluate whether the State exercised due diligence in obtaining DNA testing under the principles outlined in People v. Battles, 311 Ill.

12025–2025
People v. Marcum green
ill · 2024
1 sentence

2025“Any motion not filed within such time or an extension thereof shall not be considered by the court and the grounds therefor *** are waived.” Id. § 114-1(b). ¶ 42 In Marcum, the defendant did not file a pretrial motion to dismiss on statutory speedy-trial grounds, but argued that review was available under the plain error doctrine.

12025–2025
People v. Beyah green
ill · 1977
1 sentence

2023Beyah, 67 Ill. 2d at 428 .

12023–2023
People v. Allen green
ill · 2006
2 sentences

2022Moreover, under the second prong of the doctrine, “even constitutional errors can be forfeited [citation] if the error is not of such magnitude that it deprives the defendant of a fair trial.” Allen, 222 Ill. 2d at 352 , 856 N.E.2d at 356 . ¶ 51 As noted earlier in our analysis, the legislature has provided for the forfeiture of a statutory speedy-trial violation if the violation is not timely raised.

2022Moreover, under the second prong of the doctrine, “even constitutional errors can be forfeited [citation] if the error is not of such magnitude that it deprives the defendant of a fair trial.” Allen, 222 Ill. 2d at 352 , 856 N.E.2d at 356 . ¶ 51 As noted earlier in our analysis, the legislature has provided for the forfeiture of a statutory speedy-trial violation if the violation is not timely raised.

12022–2022
People v. Sandoval green
ill · 2010
1 sentence

2022“Any motion not filed within such time or an extension thereof shall not be considered by the court and the grounds therefor *** are waived.” Id. § 114-1(b).

12022–2022
People v. Gay green
illappct · 2007
1 sentence

2022See People v. Smith, 2016 IL App (3d) 140235, ¶¶ 10, 21 , 55 N.E.3d 719 (citing People v. McKinney, 2011 IL App (1st) 100317 , 962 N.E.2d 1084 , and simply restating what constitutes - 19 - second-prong plain error); McKinney, 2011 IL App (1st) 100317, ¶¶ 29, 31 (finding no error and simply citing People v. Gay, 376 Ill.

12022–2022
People v. Childress green
ill · 2000
1 sentence

2020Id.

12020–2020

Statutes the citing opinions construe

IL § 725 ILCS 5/103-5 (24) IL § 725 ILCS 5/114-1 (7) IL § 725 ILCS 5/122-1 (7) IL § 720 ILCS 5/12-3.05 (4) IL § 720 ILCS 5/12-3.3 (4) IL § 720 ILCS 5/18-2 (3) IL § 720 ILCS 5/24-1.2 (3) IL § 720 ILCS 570/401 (3) IL § 720 ILCS 570/402 (3) IL § 730 ILCS 5/5-8-4 (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

NY 49 (1983–2026) VA 32 (1997–2026) IL 30 (1994–2026) OH 25 (1995–2026) CA 15 (1997–2025) KS 14 (1997–2024) OR 13 (2002–2021) MS 8 (1998–2022) LA 8 (1994–2019) NV 4 (2019–2021) CO 4 (2014–2025) MD 3 (1988–2004) ID 3 (2009–2025) MT 3 (2016–2024) NM 3 (1989–1995) NE 2 (2021–2021) WI 2 (2004–2023) GA 2 (2020–2023) MO 2 (2019–2019)

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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