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27 Illinois opinions name it 1 courts 1991–2026 22 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.
| Case | Followed | Cited |
|---|---|---|
People v. Roddisgreen2 sentences2024Roddis, 2020 IL 124352, ¶¶ 55, 61 . ¶ 28 III. 2024Roddis, 2020 IL 124352, ¶¶ 55, 61 . | 3 | 4 |
People v. Mooregreen2 sentences2024People v. Moore, 207 Ill. 2d 68, 77-78 (2003). 2023Moore, 207 Ill. 2d at 79 . ¶ 65 Here, the trial court conducted an adequate preliminary inquiry when it asked the defendant to explain her allegations of ineffective assistance. | 2 | 4 |
People v. Robersongreen2 sentences2026People v. Roberson, 2021 IL App (3d) 190212, ¶ 23 . 2024See People v. Bell, 2018 IL App (1st) 151016 ; see also People v. Roberson, 2021 IL App (3d) 190212, ¶ 22 (in remanding for trial court to conduct an adequate preliminary inquiry, recognizing “it would be premature for this court to consider the remaining contentions raised in this appeal”). | 1 | 2 |
People v. Gabrysgreen1 sentence2025Cf. People v. Dean, 2012 IL App (2d) 110505 (noting although the circuit court did not expressly indicate that it was conducting a Krankel inquiry, the court was in fact conducting such an inquiry, and noting that there was no requirement that the court expressly so state); People v. Gabrys, 2013 IL App (3d) 110912, ¶ 23 (finding that after the court’s inquiry pursuant to Krankel, the court’s denial of the motion to withdraw indicated that it felt no further action was necessary on defendant’s allegations of 17 1-20-0387 ineffective assistance). | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Illinois. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
People v. Krankel
green
2 sentences2026The appellate court reversed and remanded for an adequate preliminary inquiry into defendant’s posttrial claims of ineffective assistance of counsel under People v. Krankel, 102 Ill. 2d 181 (1984). 2026ORDER ¶1 Held: The appellate court affirmed, holding the trial court conducted an adequate preliminary inquiry pursuant to People v. Krankel, 102 Ill. 2d 181 (1984), and appropriately declined to appoint new counsel. ¶2 In October 2023, defendant, Jaki Bell, was found guilty of aggravated battery following a jury trial and sentenced to seven years in prison. | 11 | 2020–2026 |
People v. Jolly
green
2 sentences2025People v. Jolly, 2014 IL 117142, ¶ 28 . ¶ 67 The record here shows that on the date of his sentencing hearing, defendant specifically told the trial court that he wished to file a “Krankel motion for ineffective assistance of counsel.” Once defendant raised the posttrial claim of ineffective assistance of trial counsel, the court was required under Krankel to conduct an adequate preliminary inquiry into the factual basis of the claim. 2021This initial step is known as a “preliminary Krankel hearing” or “preliminary Krankel inquiry.” People v. Jolly, 2014 IL 117142, ¶¶ 26-27 . ¶ 13 The operative concern of a reviewing court is whether the circuit court conducted an adequate preliminary inquiry. | 5 | 2019–2025 |
People v. Ayres
green
2 sentences2026People v. Ayres, 2017 IL 120071 , ¶ 11. 2025Ayres, 2017 IL 120071, ¶ 11 . | 2 | 2025–2026 |
People v. Jackson
green
1 sentence2026Jackson, 2020 IL 124112, ¶ 98 . | 1 | 2026–2026 |
People v. Dean
green
1 sentence2025Cf. People v. Dean, 2012 IL App (2d) 110505 (noting although the circuit court did not expressly indicate that it was conducting a Krankel inquiry, the court was in fact conducting such an inquiry, and noting that there was no requirement that the court expressly so state); People v. Gabrys, 2013 IL App (3d) 110912, ¶ 23 (finding that after the court’s inquiry pursuant to Krankel, the court’s denial of the motion to withdraw indicated that it felt no further action was necessary on defendant’s allegations of 17 1-20-0387 ineffective assistance). | 1 | 2025–2025 |
People v. Thomas
green
1 sentence2022Rather, the circuit court failed to address all of [defendant’s] claims against counsel—in particular [his] allegation that [defense counsel] did not try to get [defendant] a better plea deal due to the age of the case was clearly not addressed by the circuit court.” So, we understand defendant as contending the court failed to make an adequate preliminary inquiry only into his claim that defense counsel had made no effort to get a better plea deal. ¶ 27 Again, “[i]f a defendant does not make a valid ineffective assistance claim, [he] does not trigger the need for the trial court to inquire.” | 1 | 2022–2022 |
People v. Fultz
green
1 sentence1991(See People v. Fultz (1975), 32 Ill. | 1 | 1991–1991 |
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.
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.