prima facie case analysis (Illinois) · Go Syfert
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prima facie case analysis in Illinois

25 Illinois opinions name it 2 courts 1982–2024 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 (8)

CaseFollowedCited
First Capitol Mortgage Corp. v. Talandis Construction Corp.green
ill · 1976 · cited in 3 Illinois opinions naming this issue, 1999–2000
2 sentences

2000See First Capitol Mortgage Corp. v. Talandis Construction Corp., 63 Ill.2d 128, 133 , 345 N.E.2d 493 (1976).

2000See First Capitol Mortgage Corp. v. Talandis Construction Corp., 63 Ill.2d 128, 133 , 345 N.E.2d 493 (1976).

23
Mohanty v. St. John Heart Clinic, S.C.green
ill · 2006 · cited in 2 Illinois opinions naming this issue, 2021–2021
2 sentences

2021See Mohanty, 225 Ill. 2d at 62 .

2021See Mohanty, 225 Ill. 2d at 62 .

22
People v. Savorygreen
ill · 2001 · cited in 2 Illinois opinions naming this issue, 2015–2015
2 sentences

2015DNA testing is, of course, generally accepted in the scientific community, and so we turn to the material-relevance requirement. ¶ 31 “Evidence which is materially relevant to a claim of actual innocence is evidence which tends to significantly advance that claim, and, pursuant to the express terms of the statute, need not completely exonerate a defendant.” People v. Smith, 2014 IL App (1st) 113265, ¶ 24 (citing People v. Savory, 197 Ill. 2d 203, 213-14 (2001)).

2015DNA testing is, of course, generally accepted in the scientific community, and so we turn to the material-relevance requirement. ¶ 31 “Evidence which is materially relevant to a claim of actual innocence is evidence which tends to significantly advance that claim, and, pursuant to the express terms of the statute, need not completely exonerate a defendant.” People v. Smith, 2014 IL App (1st) 113265, ¶ 24 (citing People v. Savory, 197 Ill. 2d 203, 213-14 (2001)).

22
People v. Smithgreen
illappct · 2014 · cited in 2 Illinois opinions naming this issue, 2015–2015
2 sentences

2015DNA testing is, of course, generally accepted in the scientific community, and so we turn to the material-relevance requirement. ¶ 31 “Evidence which is materially relevant to a claim of actual innocence is evidence which tends to significantly advance that claim, and, pursuant to the express terms of the statute, need not completely exonerate a defendant.” People v. Smith, 2014 IL App (1st) 113265, ¶ 24 (citing People v. Savory, 197 Ill. 2d 203, 213-14 (2001)).

2015DNA testing is, of course, generally accepted in the scientific community, and so we turn to the material-relevance requirement. ¶ 31 “Evidence which is materially relevant to a claim of actual innocence is evidence which tends to significantly advance that claim, and, pursuant to the express terms of the statute, need not completely exonerate a defendant.” People v. Smith, 2014 IL App (1st) 113265, ¶ 24 (citing People v. Savory, 197 Ill. 2d 203, 213-14 (2001)).

22
People v. Nitzgreen
illappct · 2007 · cited in 2 Illinois opinions naming this issue, 2012–2012
2 sentences

2012See People v. Nitz, 371 Ill.App.3d 747, 750 , 309 Ill.Dec. 185 , 863 N.E.2d 817 (2007) (where the trial court granted the *960 State's motion for a directed finding on defendant's motion to quash an arrest and suppress evidence, the reviewing court stated that it must determine whether the defendant made a prima facie case so as to shift the burden of going forward to the State).

2012See People v. Nitz, 371 Ill.App.3d 747, 750 , 309 Ill.Dec. 185 , 863 N.E.2d 817 (2007) (where the trial court granted the *960 State's motion for a directed finding on defendant's motion to quash an arrest and suppress evidence, the reviewing court stated that it must determine whether the defendant made a prima facie case so as to shift the burden of going forward to the State).

22
In Matter of Goose Creek Drainage District No. 1green
illappct · 1999 · cited in 2 Illinois opinions naming this issue, 2004–2004
2 sentences

2004In re Goose Creek Drainage District No. 1, 307 Ill.

2004In re Goose Creek Drainage District No. 1 , 307 Ill.

22
Courier v. Industrial Commissiongreen
illappct · 1996 · cited in 1 Illinois opinions naming this issue, 2024–2024
1 sentence

2024People v. Relwani, 2019 IL 123385, ¶ 18 ; Courier v. Industrial Commission, 282 Ill.

11
People v. Andrewsgreen
ill · 1992 · cited in 1 Illinois opinions naming this issue, 2023–2023
1 sentence

2023Defendant does not challenge either of these findings. ¶ 21 Defendant cites the supreme court’s comment in People v. Andrews, 146 Ill. 2d 413, 427 (1992), that “[a] trial judge’s experience with local prosecutors and knowledge of local conditions are relevant factors in a prima facie case analysis.” He claims that, under Andrews, there was similar relevance in his counsel’s affidavit stating that, during his previous representation of an African American defendant, the State asked whether counsel would “ ‘play the race card.’ ” Defendant argues, in essence, that the term “race card” has racist

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 (13)

CaseCitedYears
People v. Gliniewicz green
illappct · 2018
2 sentences

2020Gliniewicz I, 2018 IL App (2d) 170490, ¶ 50 .

2020Gliniewicz I, 2018 IL App (2d) 170490, ¶ 50 .

22020–2020
Bridgestone/Firestone, Inc. v. Doherty green
illappct · 1999
2 sentences

2010Bridgestone, 305 Ill.

2010Bridgestone, 305 Ill.

22010–2010
Hernandez v. New York green
scotus · 1991
2 sentences

2004As noted in Hernandez, the prima facie case analysis is rendered moot when a neutral reason is offered “without any prompting or inquiry from the trial court.” Hernandez, 500 U.S. at 359 , 114 L.

2004As noted in Hernandez, the prima facie case analysis is rendered moot when a neutral reason is offered “without any prompting or inquiry from the trial court.” Hernandez, 500 U.S. at 359 , 114 L.

22004–2004
People v. Relwani green
ill · 2019
1 sentence

2024People v. Relwani, 2019 IL 123385, ¶ 18 ; Courier v. Industrial Commission, 282 Ill.

12024–2024
Lalvani v. ILLINOIS HUMAN RIGHTS COM'N green
illappct · 2001
1 sentence

2024The court did not consider the employer’s subjective criteria as part of the prima facie case analysis. 7 Id. at 791 .

12024–2024
People v. Gliniewicz green
illappct · 2020
2 sentences

2020The State also repeated its argument that the admissibility of the communications should be considered under the marital privilege and not under section 115-16 of the Code of Criminal Procedure of 1963 (Code) (725 ILCS 5/115-16 (West 2016)), which generally bars spouses from testifying “as to any communication or admission made by either of them to the other or as to any conversation between them during marriage[.]” The -5- 2020 IL App (2d) 190412 State also argued that defendant’s consent to search her phone was not conditioned on the type of search to be performed.

2020Defendant knew that the police wanted to search her phone to see if there were text messages or other communications about “hiding money.” Our examination of the October 8, 2015, interview confirms our holding that the State made a prima facie case of waiver. - 19 - 2020 IL App (2d) 190412 ¶ 41 During the interview, the police told defendant that they wanted to clear some things up and find out what happened to Joe.

12020–2020
People v. HOMMERSON green
illappct · 2010
2 sentences

2018App. 3d at 413 -14 , 339 Ill.Dec. 560 , 927 N.E.2d 101 (defendant waived privilege by failing to invoke it during his wife's testimony). ¶ 50 We hold that the State has, by its representations to the trial court and by the exhibits, made a prima facie case of waiver.

2018App. 3d at 413 -14 , 339 Ill.Dec. 560 , 927 N.E.2d 101 (defendant waived privilege by failing to invoke it during his wife's testimony). ¶ 50 We hold that the State has, by its representations to the trial court and by the exhibits, made a prima facie case of waiver.

12018–2018
People v. Simpson green
ill · 1977
2 sentences

2018Defendant concedes that "a voluntary revelation by the holder of the privilege of the communication, or of a material part, is a waiver of that privilege," citing Simpson , 68 Ill. 2d at 281 -82 , 12 Ill.Dec. 234 , 369 N.E.2d 1248 .

2018Defendant concedes that "a voluntary revelation by the holder of the privilege of the communication, or of a material part, is a waiver of that privilege," citing Simpson , 68 Ill. 2d at 281 -82 , 12 Ill.Dec. 234 , 369 N.E.2d 1248 .

12018–2018
People v. Smith green
illappct · 1990
2 sentences

1992App. 3d 839, 846 , 557 N.E.2d 596 .) A prima facie case of waiver is established if the State produces evidence that the defendant was properly admonished and that, after being admonished, he waived his right to assistance of counsel.

1992Smith, 199 Ill.

11992–1992
Batson v. Kentucky green
scotus · 1986
2 sentences

1992Specifically, the judge made no analysis of: whether a “pattern” of strikes against blacks was present (Batson, 476 U.S. at 97 , 90 L.

1992Specifically, the judge made no analysis of: whether a “pattern” of strikes against blacks was present (Batson, 476 U.S. at 97 , 90 L.

11992–1992
Pedrick v. Peoria & Eastern Railroad green
ill · 1967
2 sentences

1988Co. (1967), 37 Ill. 2d 494 [, 229 N.E.2d 504 ]), the court is not to view the evidence in the light most favorable to the plaintiff. *** * * * The prima facie case standard ordinarily applies to both jury and nonjury cases.

1988Co. (1967), 37 Ill. 2d 494 [, 229 N.E.2d 504 ]), the court is not to view the evidence in the light most favorable to the plaintiff. *** * * * The prima facie case standard ordinarily applies to both jury and nonjury cases.

11988–1988
Kokinis v. Kotrich green
ill · 1980
2 sentences

1987In Kokinis v. Kotrich (1980), 81 Ill. 2d 151 , 407 N.E.2d 43 , our supreme court noted that the prima facie case standard ordinarily is applicable to both jury and nonjury cases.

1987In Kokinis v. Kotrich (1980), 81 Ill. 2d 151 , 407 N.E.2d 43 , our supreme court noted that the prima facie case standard ordinarily is applicable to both jury and nonjury cases.

11987–1987
Richard Gennuso v. Commercial Bank & Trust Company green
ca3 · 1977
1 sentence

1982Plaintiff’s reliance upon Gennuso v. Commercial Bank & Trust Co. (3d Cir. 1977), 566 F.2d 437 , is misplaced.

11982–1982

Statutes the citing opinions construe

IL § 225 ILCS 460/19 (3) IL § 720 ILCS 5/8-2 (3) IL § 725 ILCS 5/115-16 (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

IN 134 (1911–2018) NY 77 (1915–2026) TX 40 (1926–2024) IL 25 (1982–2024) NC 13 (1906–2017) OH 13 (1958–2025) WA 12 (1913–2017) CA 11 (1914–2019) MI 10 (1962–2024) MO 9 (1901–2021) WI 9 (1910–2023) LA 8 (2001–2024) PA 7 (1973–2026) TN 6 (1965–2024) ND 6 (2013–2026) FL 6 (1992–2013) IA 5 (2012–2023) AL 5 (1977–2006) CO 5 (1957–2013) MA 5 (1997–2020) AZ 5 (1985–2022) NJ 4 (1998–2024) NM 4 (2017–2024) AR 4 (1993–2000) DC 3 (1987–2007) UT 3 (1989–2003) OR 3 (1954–2010) HI 2 (1939–2016) CT 2 (2001–2002) WY 2 (1978–2007) KY 2 (1922–2017)

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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