discretion defense (Illinois) · Go Syfert
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discretion defense in Illinois

28 Illinois opinions name it 2 courts 1968–2026 4 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 (12)

CaseFollowedCited
People v. Bobogreen
illappct · 2007 · cited in 5 Illinois opinions naming this issue, 2010–2020
2 sentences

2020App. 3d 884, 890 (2010) (“ ‘Defense counsel’s choice of jury instruction is considered a tactical decision, within the discretion of defense counsel.’ ” (quoting People v. Bobo, 375 Ill.

2018App. 3d 884, 890 (2010) (“ ‘Defense counsel’s choice of jury instruction is considered a tactical decision, within the discretion of defense counsel.’ ” (quoting People v. Bobo, 375 Ill.

55
People v. Shlimongreen
illappct · 1992 · cited in 3 Illinois opinions naming this issue, 2007–2023
2 sentences

2023See, e.g., People v. Shlimon, 232 Ill.

2007People v. Shlimon, 232 Ill.

33
People v. Harrisgreen
ill · 1989 · cited in 3 Illinois opinions naming this issue, 2009–2010
2 sentences

2010People v. Harris, 132 Ill. 2d 366, 391 (1989).

2010People v. Harris, 132 Ill. 2d 366, 391 (1989).

33
Wright v. Desate, Inc.green
illappct · 1997 · cited in 2 Illinois opinions naming this issue, 2018–2018
2 sentences

2018See Wright , 292 Ill.

2018See Wright, 292 Ill.

22
SUSNIS EX REL. SUSNIS v. Radfargreen
illappct · 2000 · cited in 2 Illinois opinions naming this issue, 2002–2002
2 sentences

2002See Susnis v. Radfar, 317 Ill.

2002See Susnis v. Radfar , 317 Ill.

22
People v. Maldonadogreen
illappct · 2010 · cited in 2 Illinois opinions naming this issue, 2018–2018
2 sentences

2018People v. Maldonado , 402 Ill.

2018People v. Maldonado, 402 Ill.

12
Smith v. PACE, a SUBURBAN BUS DIV.green
illappct · 2001 · cited in 1 Illinois opinions naming this issue, 2025–2025
1 sentence

2025As stated, when making such a determination, “the trial court should apply the same factors used to determine whether barring a witness is an appropriate sanction in an original action.” Id. ¶ 45; Freeman, 2018 IL App (2d) 170169, ¶ 52 (same); Smith, 323 Ill.

11
Gibellina v. Handleygreen
ill · 1989 · cited in 1 Illinois opinions naming this issue, 2025–2025
1 sentence

2025Trial courts have the discretion to rule on any motion filed before a plaintiff’s motion for voluntary dismissal if a favorable ruling on that motion “could result in a final disposition of the cause.” Id. § 2-1009(b); Gibellina v. Handley, 127 Ill. 2d 122, 137-38 (1989).

11
Freeman v. Craysgreen
illappct · 2018 · cited in 1 Illinois opinions naming this issue, 2025–2025
1 sentence

2025As stated, when making such a determination, “the trial court should apply the same factors used to determine whether barring a witness is an appropriate sanction in an original action.” Id. ¶ 45; Freeman, 2018 IL App (2d) 170169, ¶ 52 (same); Smith, 323 Ill.

11
Boehle v. OSF Healthcare Systemgreen
illappct · 2018 · cited in 1 Illinois opinions naming this issue, 2025–2025
2 sentences

2025See Ritschel Boehle, 2018 IL App (2d) 160975, ¶¶ 44-45 (holding that although a plaintiff may “use a voluntary dismissal to attempt to avoid the consequences of a court order,” and nothing prevents a plaintiff from disclosing a new witness in a refiled action, the trial court still must consider prior litigation when a case is refiled and has “the discretion to bar or otherwise limit certain witnesses and/or evidence in the refiled action” (emphasis in original)). ¶ 54 As the trial court clearly had the authority to consider the prior litigation in the underlying refiled case and the discretio

2025See Ritschel Boehle, 2018 IL App (2d) 160975, ¶¶ 44-45 (holding that although a plaintiff may “use a voluntary dismissal to attempt to avoid the consequences of a court order,” and nothing prevents a plaintiff from disclosing a new witness in a refiled action, the trial court still must consider prior litigation when a case is refiled and has “the discretion to bar or otherwise limit certain witnesses and/or evidence in the refiled action” (emphasis in original)). ¶ 54 As the trial court clearly had the authority to consider the prior litigation in the underlying refiled case and the discretio

11
People v. Mimsgreen
illappct · 2010 · cited in 1 Illinois opinions naming this issue, 2020–2020
1 sentence

2020See Illinois Pattern Jury Instructions, Criminal, Nos. 14.05, 14.06 (approved Jan. 24, 2014) (hereinafter IPI Criminal Nos. 14.05, 14.06). ¶ 47 “ ‘Defense counsel’s choice of jury instruction is considered a tactical decision, within the discretion of defense counsel.’ ” People v. Mims, 403 Ill.

11
People v. Wallacegreen
illappct · 2016 · cited in 1 Illinois opinions naming this issue, 2020–2020
1 sentence

2020See Wallace, 2016 IL App (1st) 142758, ¶ 26 .

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 (9)

CaseCitedYears
Combs v. Steele neutral
ill · 1875
2 sentences

1975(Combs v. Steele, 80 Ill. 101 .) Factors relevant to the exercise of this discretion are the subject matter under litigation, the reason for the dismissal, and the consequences thereof.

1975Further mitigation against adhering to an inflexible application of this rule stems from the realization that the dismissal of an action for want of prosecution is within the discretion of the hearing court, with the right to reinstate likewise being a matter of judicial discretion. ( Combs v. Steele, 80 Ill. 101 .) Factors relevant to the exercise of this discretion are the subject matter under litigation, the reason for the dismissal, and the consequences thereof.

31968–1975
Froehlich v. Sheehan green
illappct · 1992
2 sentences

2003Froehlich v. Sheehan, 240 Ill.

2003Froehlich v. Sheehan , 240 Ill.

22003–2003
People v. Jackson green
ill · 2020
1 sentence

2026People v. Jackson, 2020 IL 124112, ¶ 106 .

12026–2026
People v. Utley green
illappct · 2019
1 sentence

2020The Omitted Pro Se Claim That Trial Counsel Rendered Ineffective Assistance by Not Filing a Motion to Suppress Defendant’s Statements to the Police ¶ 62 In the amended postconviction petition, Farrington gave an explanation for declining to pursue the pro se claim that Schmidt had rendered ineffective assistance by failing to move for the suppression of defendant’s statements to the police. “[I]t is well settled,” Farrington wrote, “that defense counsel’s choice of what motions will be filed is considered a tactical decision and within the discretion of defense counsel.” And yet, defendant obs

12020–2020
People v. Kuehner green
ill · 2015
1 sentence

2020Farrington wrote: “Governed by the recent Illinois Supreme Court case of People v. Kuehner, 2015 IL 117695 , the undersigned attorney cannot sign this pleading as to each of the following claims because of a professional inability to pursue claims believed to be meritless.” ¶ 25 The first pro se claim that Farrington declined to adopt was the claim of “[i]neffective assistance of trial counsel for failure to file a Motion to Suppress.” Farrington explained: “The undersigned attorney believes this claim to be meritless because it is well settled that defense counsel’s choice of what motions wil

12020–2020
People v. McKendrick green
illappct · 1985
1 sentence

1988(People v. McKendrick (1985), 138 Ill.

11988–1988
Thiele v. Kennedy green
illappct · 1974
1 sentence

1986(Thiele v. Kennedy (1974), 18 Ill.

11986–1986
McCormick v. Burt green
ill · 1880
1 sentence

1986In Thiele, on which the board relies, the court cites McCormick v. Burt (1880), 95 Ill. 263 , an early enunciation of the discretion immunity rule, as authority for the proposition that the only exception to discretion immunity is one for acts based on corrupt or malicious motives.

11986–1986
The PEOPLE v. Brown green
ill · 1968
1 sentence

1975In the instant case the subject matter is the propriety of defendant's criminal trial, the grounds for dismissal, *582 the defendant's attorney's inaction and the consequences thereof — the denial of defendant's right to appeal." 39 Ill.2d 307, 310-11 .

11975–1975

Statutes the citing opinions construe

IL § 735 ILCS 5/2-1009 (4) IL § 720 ILCS 5/9-1 (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.

Where else courts name it

NY 100 (1912–2026) TX 62 (1956–2025) CA 41 (1959–2026) PA 36 (1948–2026) FL 30 (1963–2025) MA 28 (1893–2026) IL 28 (1968–2026) OH 21 (1993–2026) AL 12 (1911–2015) IA 12 (1971–2023) CO 12 (1983–2014) NM 11 (1967–2015) WA 11 (1978–2025) MO 11 (1975–2022) GA 11 (1924–2024) CT 10 (1945–2022) MD 9 (1968–2021) VT 9 (1925–2021) LA 9 (1979–2013) IN 8 (1913–2011) RI 7 (1997–2023) AR 7 (1984–2023) SC 6 (1953–2017) NE 6 (1977–2020) WY 6 (1991–2024) NJ 6 (1985–2024) AK 5 (1988–2022) MN 5 (1955–2024) WV 5 (1996–2022) MI 5 (1976–2023) KY 4 (1981–2020) OR 4 (1969–2008) AZ 4 (1977–1996) HI 3 (1995–2021) UT 3 (1997–2025) MT 3 (1989–2007) DE 3 (1939–2015) KS 3 (2005–2024) NC 3 (1926–2024) VI 2 (1992–2011) WI 2 (1979–1987) DC 2 (1997–2007) MS 2 (1986–2003) OK 2 (1982–2004) ME 2 (1986–1990) ID 2 (1993–2017)

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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