unanimity requirement (Illinois) · Go Syfert
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unanimity requirement in Illinois

24 Illinois opinions name it 2 courts 1984–2025 2 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 (15)

CaseFollowedCited
People v. MacRigreen
ill · 1998 · cited in 4 Illinois opinions naming this issue, 1999–2000
2 sentences

2000See Buss, 187 Ill. 2d at 235 (the circuit court did not err in refusing the defendant’s mercy instruction when the jury received IPI Criminal 3d No. 7C.06); Macri, 185 Ill. 2d at 70-71 (the circuit court did not err in refusing the defendant’s unanimity instruction when the jury received IPI Criminal 3d No. 7C.05).

2000See Buss, 187 Ill.2d at 235 , 240 Ill.Dec. 520 , 718 N.E.2d 1 (the circuit court did not err in refusing the defendant's mercy instruction when the jury received IPI Criminal 3d No. 7C.06); Macri, 185 Ill.2d at 70-71, 235 Ill.Dec. 589 , 705 N.E.2d 772 (the circuit court did not err in refusing the defendant's unanimity instruction when the jury received IPI Criminal 3d No. 7C.05).

44
People v. Buggsgreen
ill · 1986 · cited in 3 Illinois opinions naming this issue, 1986–1988
2 sentences

1988As I have stated before ( People v. Hall (1986), 114 Ill.2d 376, 422 (Simon, J., concurring in part and dissenting in part); People v. Buggs (1986), 112 Ill.2d 284, 296 (Simon, J., specially *92 concurring)), fundamental fairness requires that trial judges correctly inform all capital defendants of the unanimity requirement before accepting jury waivers at death sentencing hearings.

1988As I have stated before (People v. Hall (1986), 114 Ill. 2d 376, 422 (Simon, J., concurring in part and dissenting in part); People v. Buggs (1986), 112 Ill. 2d 284, 296 (Simon, J., specially concurring)), fundamental fairness requires that trial judges correctly inform all capital defendants of the unanimity requirement before accepting jury waivers at death sentencing hearings.

23
People v. Salazargreen
ill · 1988 · cited in 2 Illinois opinions naming this issue, 2007–2007
2 sentences

2007A jury instruction is “ ‘to convey to the minds of the jury the correct principles of law applicable to the evidence submitted to it.’ ” People v. Salazar, 126 Ill. 2d 424, 464 (1988), quoting People v. Gambony, 402 Ill. 74, 81-82 (1948).

2007A jury instruction is “ ‘to convey to the minds of the jury the correct principles of law applicable to the evidence submitted to it.’ ” People v. Salazar, 126 Ill. 2d 424, 464 (1988), quoting People v. Gambony, 402 Ill. 74, 81-82 (1948).

22
The People v. Gambonygreen
ill · 1948 · cited in 2 Illinois opinions naming this issue, 2007–2007
2 sentences

2007A jury instruction is “ ‘to convey to the minds of the jury the correct principles of law applicable to the evidence submitted to it.’ ” People v. Salazar, 126 Ill. 2d 424, 464 (1988), quoting People v. Gambony, 402 Ill. 74, 81-82 (1948).

2007A jury instruction is “ ‘to convey to the minds of the jury the correct principles of law applicable to the evidence submitted to it.’ ” People v. Salazar, 126 Ill. 2d 424, 464 (1988), quoting People v. Gambony, 402 Ill. 74, 81-82 (1948).

22
People v. Bussgreen
ill · 1999 · cited in 2 Illinois opinions naming this issue, 2000–2000
2 sentences

2000See Buss, 187 Ill. 2d at 235 (the circuit court did not err in refusing the defendant’s mercy instruction when the jury received IPI Criminal 3d No. 7C.06); Macri, 185 Ill. 2d at 70-71 (the circuit court did not err in refusing the defendant’s unanimity instruction when the jury received IPI Criminal 3d No. 7C.05).

2000See Buss, 187 Ill.2d at 235 , 240 Ill.Dec. 520 , 718 N.E.2d 1 (the circuit court did not err in refusing the defendant's mercy instruction when the jury received IPI Criminal 3d No. 7C.06); Macri, 185 Ill.2d at 70-71, 235 Ill.Dec. 589 , 705 N.E.2d 772 (the circuit court did not err in refusing the defendant's unanimity instruction when the jury received IPI Criminal 3d No. 7C.05).

22
People v. Albanesegreen
ill · 1984 · cited in 2 Illinois opinions naming this issue, 1986–1990
2 sentences

1990See also People v. Albanese (1984), 104 Ill. 2d 504, 535-36 (where this court held that the Constitution does not require that the trial court inform the defendant of the unanimity requirement).) The cases cited by the majority stand for the proposition that a trial court’s failure to inform the defendant of the need for juror unanimity, which is not a constitutional requirement, can be overcome by a showing that the defendant consulted with his attorney, that the defendant said he understands the consequences of waiving the jury, and that defendant’s attorney said he believes the defendant’s

1990See also People v. Albanese (1984), 104 Ill.2d 504, 535-36 , 85 Ill.Dec. 441 , 473 N.E.2d 1246 (where this court held that the Constitution does not require that the trial court inform the defendant of the unanimity requirement).) The cases cited by the majority stand for the proposition that a trial court's failure to inform the defendant of the need for juror unanimity, which is not a constitutional *1278 requirement, can be overcome by a showing that the defendant consulted with his attorney, that the defendant said he understands the consequences of waiving the jury, and that defendant's a

12
People v. Morgangreen
ill · 1986 · cited in 2 Illinois opinions naming this issue, 1986–1988
2 sentences

1988This court has previously taken the position that it is the responsibility of the defendant's attorney to be certain that the defendant understood the rule and that his waiver was knowing and intelligent. ( People v. Morgan (1986), 112 Ill.2d 111, 142 .) This case, however, illustrates the problem with that approach because there is no evidence in the record that the defendant's attorney explained the unanimity requirement to him.

1988(People v. Morgan (1986), 112 Ill. 2d 111, 142 .) This case, however, illustrates the problem with that approach because there is no evidence in the record that the defendant’s attorney explained the unanimity requirement to him.

12
Ramos v. Louisianagreen
scotus · 2020 · cited in 1 Illinois opinions naming this issue, 2025–2025
1 sentence

2025Ramos v. Louisiana, 590 U.S. 83, 90 (2020).

11
United States v. Applinsgreen
ca2 · 2011 · cited in 1 Illinois opinions naming this issue, 2024–2024
1 sentence

2024See United States v. Applins, 637 F.3d 59, 82 (2d Cir. 2011) (“[W]e conclude that the district court’s instruction was sufficient in requiring unanimity as to the types of predicate racketeering acts that the defendants agreed to commit without requiring a finding of specific predicate acts.” (Emphasis added.)); United States v. Hein, 395 F. App’x 652, 656 (11th Cir. 2010) (“[The] argument that the jury had to unanimously agree on particular and individual acts and not just the general types of predicate offenses is not supported by the law and thus was not required in a jury instruction.”); U

11
United States v. Daniel P. Gleciergreen
ca7 · 1991 · cited in 1 Illinois opinions naming this issue, 2024–2024
1 sentence

2024See United States v. Applins, 637 F.3d 59, 82 (2d Cir. 2011) (“[W]e conclude that the district court’s instruction was sufficient in requiring unanimity as to the types of predicate racketeering acts that the defendants agreed to commit without requiring a finding of specific predicate acts.” (Emphasis added.)); United States v. Hein, 395 F. App’x 652, 656 (11th Cir. 2010) (“[The] argument that the jury had to unanimously agree on particular and individual acts and not just the general types of predicate offenses is not supported by the law and thus was not required in a jury instruction.”); U

11
United States v. Steve Heingreen
ca11 · 2010 · cited in 1 Illinois opinions naming this issue, 2024–2024
1 sentence

2024See United States v. Applins, 637 F.3d 59, 82 (2d Cir. 2011) (“[W]e conclude that the district court’s instruction was sufficient in requiring unanimity as to the types of predicate racketeering acts that the defendants agreed to commit without requiring a finding of specific predicate acts.” (Emphasis added.)); United States v. Hein, 395 F. App’x 652, 656 (11th Cir. 2010) (“[The] argument that the jury had to unanimously agree on particular and individual acts and not just the general types of predicate offenses is not supported by the law and thus was not required in a jury instruction.”); U

11
People v. Rameygreen
ill · 1992 · cited in 1 Illinois opinions naming this issue, 1994–1994
2 sentences

1994See Erickson, 117 Ill. 2d at 295-96 ; see also People v. Ramey (1992), 152 Ill. 2d 41, 59-60 (holding that knowledge of the unanimity requirement is immaterial to assessment of whether a defendant’s waiver of a jury for sentencing is valid).

1994See Erickson, 117 Ill.2d at 295-96 , 111 Ill.Dec. 924 , 513 N.E.2d 367 ; see also People v. Ramey (1992), 152 Ill.2d 41, 59-60 , 178 Ill.Dec. 19 , 604 N.E.2d 275 (holding *462 that knowledge of the unanimity requirement is immaterial to assessment of whether a defendant's waiver of a jury for sentencing is valid).

11
People v. Ericksongreen
ill · 1987 · cited in 1 Illinois opinions naming this issue, 1994–1994
2 sentences

1994(See Erickson, 117 Ill. 2d at 295-96 .) However, he insists a different issue is raised here: whether an evidentiary hearing is required because he generated a sworn statement revealing he did not truly understand the unanimity requirement.

1994See Erickson, 117 Ill. 2d at 295-96 ; see also People v. Ramey (1992), 152 Ill. 2d 41, 59-60 (holding that knowledge of the unanimity requirement is immaterial to assessment of whether a defendant’s waiver of a jury for sentencing is valid).

11
People v. Hendersongreen
ill · 1990 · cited in 1 Illinois opinions naming this issue, 1990–1990
2 sentences

1990See also People v. Albanese (1984), 104 Ill.2d 504, 535-36 , 85 Ill.Dec. 441 , 473 N.E.2d 1246 (where this court held that the Constitution does not require that the trial court inform the defendant of the unanimity requirement).) The cases cited by the majority stand for the proposition that a trial court's failure to inform the defendant of the need for juror unanimity, which is not a constitutional *1278 requirement, can be overcome by a showing that the defendant consulted with his attorney, that the defendant said he understands the consequences of waiving the jury, and that defendant's a

1990See also People v. Albanese (1984), 104 Ill.2d 504, 535-36 , 85 Ill.Dec. 441 , 473 N.E.2d 1246 (where this court held that the Constitution does not require that the trial court inform the defendant of the unanimity requirement).) The cases cited by the majority stand for the proposition that a trial court's failure to inform the defendant of the need for juror unanimity, which is not a constitutional *1278 requirement, can be overcome by a showing that the defendant consulted with his attorney, that the defendant said he understands the consequences of waiving the jury, and that defendant's a

11
People v. Hallgreen
ill · 1986 · cited in 1 Illinois opinions naming this issue, 1988–1988
2 sentences

1988As I have stated before ( People v. Hall (1986), 114 Ill.2d 376, 422 (Simon, J., concurring in part and dissenting in part); People v. Buggs (1986), 112 Ill.2d 284, 296 (Simon, J., specially *92 concurring)), fundamental fairness requires that trial judges correctly inform all capital defendants of the unanimity requirement before accepting jury waivers at death sentencing hearings.

1988As I have stated before (People v. Hall (1986), 114 Ill. 2d 376, 422 (Simon, J., concurring in part and dissenting in part); People v. Buggs (1986), 112 Ill. 2d 284, 296 (Simon, J., specially concurring)), fundamental fairness requires that trial judges correctly inform all capital defendants of the unanimity requirement before accepting jury waivers at death sentencing hearings.

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 (14)

CaseCitedYears
People v. Gilliam green
ill · 1996
2 sentences

1998“An abuse of discretion in the refusal of a non-IPI instruction occurs only when there is no IPI instruction that applies to the subject on which the jury would have been instructed.” Gilliam, 172 Ill. 2d at 519 .

1998“An abuse of discretion in the refusal of a non-IPI instruction occurs only when there is no IPI instruction that applies to the subject on which the jury would have been instructed.” Gilliam , 172 Ill. 2d at 519 .

21998–1998
People v. Winkle green
calctapp · 1988
2 sentences

1997Winkle, 206 Cal. App. 3d at 830 , 253 Cal. Rptr. at 730 .

1997Winkle, 206 Cal. App. 3d at 830 , 253 Cal. Rptr. at 730 .

21997–1997
People v. Madej green
ill · 1985
2 sentences

1986Waiver of the sentencing jury is valid if it is made voluntarily and knowingly. ( People v. King (1986), 109 Ill.2d 514, 546 ; People v. Madej (1985), 106 Ill.2d 201, 220-21 , cert. denied (1985), 474 U.S. 935 , 88 L.Ed.2d 274 , 106 S.Ct. 268 .) This court has made it clear that waiver of the sentencing jury can be voluntary and intelligent even where the trial court does not explain the unanimity requirement to the defendant prior to accepting the waiver.

1986This court has repeatedly declined to adopt a rule that would expressly require our circuit courts to inform all defendants of the unanimity requirement before accepting jury waivers at death sentencing hearings. ( People v. Madej (1985), 106 Ill.2d 201, 220-21 ; People v. Albanese (1984), 104 Ill.2d 504, 535 ; People v. Brownell (1980), 79 Ill.2d 508, 536 .) We continue to believe that the sixth amendment does not require a precise formula for determining whether a waiver has been knowingly and intelligently made.

21986–1986
People v. Brownell green
ill · 1980
2 sentences

1986This court has repeatedly declined to adopt a rule that would expressly require our circuit courts to inform all defendants of the unanimity requirement before accepting jury waivers at death sentencing hearings. ( People v. Madej (1985), 106 Ill.2d 201, 220-21 ; People v. Albanese (1984), 104 Ill.2d 504, 535 ; People v. Brownell (1980), 79 Ill.2d 508, 536 .) We continue to believe that the sixth amendment does not require a precise formula for determining whether a waiver has been knowingly and intelligently made.

1984ALBANESE: No.” Defendant notes that in People v. Brownell (1980), 79 Ill. 2d 508, 536 , this court declined to adopt a rule that would have expressly required our trial courts to inform all defendants of the unanimity requirement before accepting waivers of juries at capital sentencing hearings, and he urges that we now establish such a rule.

21984–1986
People v. Prim green
ill · 1972
1 sentence

2025In People v. Prim, 53 Ill. 2d 62 (1972), the court 10 considered how to proceed when a jury informs the court that it is deadlocked.

12025–2025
People v. Bannister green
ill · 2008
2 sentences

2008The majority specifically relies on the presence of the correct unanimity standard in the no-death verdict form, noting that " had the jury chosen to sign a no-death verdict, it would have signed a piece of paper recognizing that one or more of the jurors had determined that death was not the appropriate sentence." (Emphasis added.) 232 Ill.2d at 87 , 327 Ill.Dec. at 471-72 , 902 N.E.2d at 592-93 .

2008The majority specifically relies on the presence of the correct unanimity standard in the no-death verdict form, noting that " had the jury chosen to sign a no-death verdict, it would have signed a piece of paper recognizing that one or more of the jurors had determined that death was not the appropriate sentence." (Emphasis added.) 232 Ill.2d at 87 , 327 Ill.Dec. at 471-72 , 902 N.E.2d at 592-93 .

12008–2008
Mills v. Maryland green
scotus · 1988
1 sentence

1995Ed. 2d at 400-03 , 108 S. Ct. at 1870-72 .) The verdict form in Mills further asked the jury to affirm or deny that it unanimously found that the mitigating circumstances marked "yes” outweighed the aggravating circumstances, and the trial court’s instruction of the jury in that case emphasized the unanimity requirement.

11995–1995
People v. Simms green
ill · 1991
1 sentence

1994(People v. Simms (1991), 143 Ill. 2d 154, 173 .) In this category is the argument that defendant was denied a fair hearing at the eligibility phase of sentencing because the jury may have become confused by contradictory statements of the prosecutor and defense counsel regarding the unanimity requirement.

11994–1994
Williams v. Florida green
scotus · 1970
2 sentences

1990Ed. 2d at 454 , 90 S. Ct. at 1900 .) The Williams Court further reasoned that the number should be large enough to obtain a representative cross-section of the community and there is no reason why this cannot be achieved as reliably when the jury numbers six than when it numbers 12, especially if the unanimity requirement is retained.

1990Williams, 399 U.S. at 100 , 26 L.

11990–1990
People v. Guest green
ill · 1986
1 sentence

1988(People v. Guest (1986), 115 Ill. 2d 72, 107 , cert. denied (1987), 483 U.S. 1010 , 97 L.

11988–1988
Department of Banking & Consumer Finance v. Clarke green
scotus · 1987
1 sentence

1988(People v. Guest (1986), 115 Ill. 2d 72, 107 , cert. denied (1987), 483 U.S. 1010 , 97 L.

11988–1988
People v. King green
ill · 1986
1 sentence

1986Waiver of the sentencing jury is valid if it is made voluntarily and knowingly. ( People v. King (1986), 109 Ill.2d 514, 546 ; People v. Madej (1985), 106 Ill.2d 201, 220-21 , cert. denied (1985), 474 U.S. 935 , 88 L.Ed.2d 274 , 106 S.Ct. 268 .) This court has made it clear that waiver of the sentencing jury can be voluntary and intelligent even where the trial court does not explain the unanimity requirement to the defendant prior to accepting the waiver.

11986–1986
Cataldo v. Meskill green
scotus · 1985
1 sentence

1986Waiver of the sentencing jury is valid if it is made voluntarily and knowingly. ( People v. King (1986), 109 Ill.2d 514, 546 ; People v. Madej (1985), 106 Ill.2d 201, 220-21 , cert. denied (1985), 474 U.S. 935 , 88 L.Ed.2d 274 , 106 S.Ct. 268 .) This court has made it clear that waiver of the sentencing jury can be voluntary and intelligent even where the trial court does not explain the unanimity requirement to the defendant prior to accepting the waiver.

11986–1986
Prudential-Bache Securities Inc. v. Angelastro red
scotus · 1985
1 sentence

1986Waiver of the sentencing jury is valid if it is made voluntarily and knowingly. ( People v. King (1986), 109 Ill.2d 514, 546 ; People v. Madej (1985), 106 Ill.2d 201, 220-21 , cert. denied (1985), 474 U.S. 935 , 88 L.Ed.2d 274 , 106 S.Ct. 268 .) This court has made it clear that waiver of the sentencing jury can be voluntary and intelligent even where the trial court does not explain the unanimity requirement to the defendant prior to accepting the waiver.

11986–1986

Statutes the citing opinions construe

IL § 720 ILCS 5/9-1 (3) IL § 725 ILCS 5/119-5 (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

CA 664 (1982–2026) TX 252 (2000–2026) WA 244 (1973–2026) KS 96 (1993–2026) MI 92 (1975–2026) MA 75 (1975–2026) CT 53 (1986–2026) HI 50 (1996–2025) NJ 48 (1975–2026) UT 42 (1987–2026) CO 41 (1984–2025) NC 38 (1988–2022) KY 30 (1971–2025) DC 30 (1983–2017) WI 29 (1979–2025) LA 26 (1996–2024) MT 24 (1980–2025) IL 24 (1984–2025) ID 23 (1978–2019) DE 22 (1988–2025) OR 22 (1969–2026) AL 20 (1997–2025) MD 19 (1961–2025) TN 15 (1991–2025) IN 15 (2002–2025) OH 15 (2000–2026) MN 14 (2001–2017) AZ 12 (1995–2023) ME 12 (1983–2025) MO 11 (2011–2024) FL 10 (1972–2026) SD 9 (2009–2024) VT 7 (2006–2024) AK 7 (1985–2020) WY 7 (1980–2025) MS 6 (1990–2013) GA 6 (1996–2023) OK 5 (1994–2023) PA 4 (1973–2016) NH 4 (1999–2024) NM 4 (1970–2023) IA 3 (2017–2024) RI 3 (2016–2019) VA 2 (2011–2019) WV 2 (1890–1918) NY 2 (1998–2020) ND 2 (2015–2015)

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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