fruit-of-the-poisonous-tree doctrine (Illinois) · Go Syfert
← Illinois issues

fruit-of-the-poisonous-tree doctrine in Illinois

23 Illinois opinions name it 2 courts 1972–2023 1 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 (16)

CaseFollowedCited
Illinois v. Krullgreen
scotus · 1987 · cited in 7 Illinois opinions naming this issue, 2015–2019
2 sentences

2019Illinois v. Krull , 480 U.S. 340 , 347, 107 S.Ct. 1160 , 94 L.Ed.2d 364 (1987). ¶ 36 "The fruit-of-the-poisonous tree doctrine is an outgrowth of the exclusionary rule providing that 'the fourth amendment violation is deemed the "poisonous tree," and any evidence obtained by exploiting that violation is subject to suppression as the "fruit" of that poisonous tree.' " People v. Burns , 2016 IL 118973 , ¶ 47, 401 Ill.Dec. 468 , 50 N.E.3d 610 (quoting People v. Henderson , 2013 IL 114040 , ¶ 33, 370 Ill.Dec. 804 , 989 N.E.2d 192 ).

2019Illinois v. Krull , 480 U.S. 340 , 347, 107 S.Ct. 1160 , 94 L.Ed.2d 364 (1987). ¶ 36 "The fruit-of-the-poisonous tree doctrine is an outgrowth of the exclusionary rule providing that 'the fourth amendment violation is deemed the "poisonous tree," and any evidence obtained by exploiting that violation is subject to suppression as the "fruit" of that poisonous tree.' " People v. Burns , 2016 IL 118973 , ¶ 47, 401 Ill.Dec. 468 , 50 N.E.3d 610 (quoting People v. Henderson , 2013 IL 114040 , ¶ 33, 370 Ill.Dec. 804 , 989 N.E.2d 192 ).

57
People v. Burnsgreen
ill · 2016 · cited in 8 Illinois opinions naming this issue, 2018–2019
2 sentences

2019Illinois v. Krull , 480 U.S. 340 , 347, 107 S.Ct. 1160 , 94 L.Ed.2d 364 (1987). ¶ 36 "The fruit-of-the-poisonous tree doctrine is an outgrowth of the exclusionary rule providing that 'the fourth amendment violation is deemed the "poisonous tree," and any evidence obtained by exploiting that violation is subject to suppression as the "fruit" of that poisonous tree.' " People v. Burns , 2016 IL 118973 , ¶ 47, 401 Ill.Dec. 468 , 50 N.E.3d 610 (quoting People v. Henderson , 2013 IL 114040 , ¶ 33, 370 Ill.Dec. 804 , 989 N.E.2d 192 ).

2019Illinois v. Krull , 480 U.S. 340 , 347, 107 S.Ct. 1160 , 94 L.Ed.2d 364 (1987). ¶ 36 "The fruit-of-the-poisonous tree doctrine is an outgrowth of the exclusionary rule providing that 'the fourth amendment violation is deemed the "poisonous tree," and any evidence obtained by exploiting that violation is subject to suppression as the "fruit" of that poisonous tree.' " People v. Burns , 2016 IL 118973 , ¶ 47, 401 Ill.Dec. 468 , 50 N.E.3d 610 (quoting People v. Henderson , 2013 IL 114040 , ¶ 33, 370 Ill.Dec. 804 , 989 N.E.2d 192 ).

38
People v. Hendersongreen
ill · 2013 · cited in 14 Illinois opinions naming this issue, 2015–2019
2 sentences

2019Illinois v. Krull , 480 U.S. 340 , 347, 107 S.Ct. 1160 , 94 L.Ed.2d 364 (1987). ¶ 36 "The fruit-of-the-poisonous tree doctrine is an outgrowth of the exclusionary rule providing that 'the fourth amendment violation is deemed the "poisonous tree," and any evidence obtained by exploiting that violation is subject to suppression as the "fruit" of that poisonous tree.' " People v. Burns , 2016 IL 118973 , ¶ 47, 401 Ill.Dec. 468 , 50 N.E.3d 610 (quoting People v. Henderson , 2013 IL 114040 , ¶ 33, 370 Ill.Dec. 804 , 989 N.E.2d 192 ).

2019As this court recognized in Burns: “The fruit-of-the-poisonous-tree doctrine is an outgrowth of the exclusionary rule providing that ‘the fourth amendment violation is deemed the “poisonous tree,” and any evidence obtained by exploiting that violation is subject to suppression as the “fruit” of that poisonous tree.’ ” Burns, 2016 IL 118973, ¶ 47 (quoting People v. Henderson, 2013 IL 114040, ¶ 33 ). “[T]he ‘prime purpose’ of the exclusionary rule ‘is to deter future unlawful police conduct and thereby effectuate the guarantee of the Fourth Amendment against unreasonable searches and seizures.’

214
Wong Sun v. United Statesgreen
scotus · 1963 · cited in 4 Illinois opinions naming this issue, 1972–2006
2 sentences

2006For this proposition, defendant relied on the fruit-of-the-poisonous-tree doctrine discussed in Wong Sun v. United States, 371 U.S. 471, 484-85 , 9 L.

2006For this proposition, defendant relied on the fruit-of-the-poisonous-tree doctrine discussed in Wong Sun v. United States, 371 U.S. 471, 484-85 , 9 L.

24
United States v. Calandragreen
scotus · 1974 · cited in 3 Illinois opinions naming this issue, 2016–2019
2 sentences

2019As this court recognized in Burns: “The fruit-of-the-poisonous-tree doctrine is an outgrowth of the exclusionary rule providing that ‘the fourth amendment violation is deemed the “poisonous tree,” and any evidence obtained by exploiting that violation is subject to suppression as the “fruit” of that poisonous tree.’ ” Burns, 2016 IL 118973, ¶ 47 (quoting People v. Henderson, 2013 IL 114040, ¶ 33 ). “[T]he ‘prime purpose’ of the exclusionary rule ‘is to deter future unlawful police conduct and thereby effectuate the guarantee of the Fourth Amendment against unreasonable searches and seizures.’

2018As this Court recognized in Burns : "The fruit-of-the-poisonous-tree doctrine is an outgrowth of the exclusionary rule providing that 'the fourth amendment violation is deemed the "poisonous tree," and any evidence obtained by exploiting that violation is subject to suppression as the "fruit" of that poisonous tree.' " Burns , 2016 IL 118973 , ¶ 47, 401 Ill.Dec. 468 , 50 N.E.3d 610 (quoting People v. Henderson , 2013 IL 114040 , ¶ 33, 370 Ill.Dec. 804 , 989 N.E.2d 192 ). "[T]he 'prime purpose' of the exclusionary rule 'is to deter future unlawful police conduct and thereby effectuate the guara

23
People v. Browngreen
illappct · 2003 · cited in 2 Illinois opinions naming this issue, 2015–2015
2 sentences

2015See, e.g., People v. Brown, 345 Ill.

2015See, e.g., People v. Brown, 345 Ill.

22
People v. Mosleygreen
illappct · 1978 · cited in 2 Illinois opinions naming this issue, 2006–2006
2 sentences

2006People v. Mosley, 63 Ill.

2006People v. Mosley, 63 Ill.

22
People v. Gervasigreen
ill · 1982 · cited in 2 Illinois opinions naming this issue, 2006–2006
2 sentences

2006The supreme court in People v. Gervasi, 89 Ill. 2d 522, 528 (1982), adopted the test used in Wong Sun to determine whether evidence is the fruit of the poisonous tree: “We need not hold that all evidence is ‘fruit of the poisonous tree’ simply because it would not have come to light but for the illegal actions of the police.

2006Gervasi, 89 Ill. 2d at 530-31 .

22
The PEOPLE v. Maslowskygreen
ill · 1966 · cited in 2 Illinois opinions naming this issue, 2006–2006
2 sentences

2006In People v. Maslowsky, 34 Ill. 2d 456, 464-65 (1966), the supreme court held that the fruit-of-the-poisonous-tree doctrine was expressly included in the eavesdropping statute.

2006In People v. Maslowsky, 34 Ill. 2d 456, 464-65 (1966), the supreme court held that the fruit-of-the-poisonous-tree doctrine was expressly included in the eavesdropping statute.

22
Davis v. United Statesgreen
scotus · 2011 · cited in 2 Illinois opinions naming this issue, 2018–2019
2 sentences

2019The good-faith exception to the exclusionary rule is a judicially created rule providing that evidence obtained in violation of a defendant’s fourth amendment rights will not be suppressed when “police acted with an ‘ “objectively ‘reasonable good-faith belief’ that their conduct [was] lawful,” ’ or when their conduct involved only simple, isolated negligence.” People v. LeFlore, 2015 IL 116799 , ¶ 24 (quoting United States v. Katzin, 769 F.3d 163, 171 (3d Cir. 2014), quoting Davis v. United States, 564 U.S. 229, 238 (2011), quoting United States v. Leon, 468 U.S. 897, 909 (1984)). ¶ 36 This “

2018The good-faith exception to the exclusionary rule is a judicially created rule providing that evidence obtained in violation of a defendant's fourth amendment rights will not be suppressed when "police acted with an " 'objectively 'reasonable good-faith belief' that their conduct [was] lawful,' " or when their conduct involved only simple, isolated negligence." People v. LeFlore , 2015 IL 116799 , ¶ 24, 392 Ill.Dec. 467 , 32 N.E.3d 1043 (quoting United States v. Katzin , 769 F.3d 163 , 171 (2014), quoting Davis v. United States , 564 U.S. 229 , 238, 131 S.Ct. 2419 , 180 L.Ed.2d 285 (2011), quo

12
People v. Sutherlandgreen
ill · 2006 · cited in 2 Illinois opinions naming this issue, 2019–2019
2 sentences

2019People v. Sutherland , 223 Ill. 2d 187 , 227, 307 Ill.Dec. 524 , 860 N.E.2d 178 (2006). ¶ 22 "The fruit-of-the-poisonous-tree doctrine is an outgrowth of the exclusionary rule providing that 'the fourth amendment violation is deemed the "poisonous tree," and any evidence obtained by exploiting that violation is subject to suppression as the "fruit" of that poisonous tree.' " People v. Burns , 2016 IL 118973 , ¶ 47, 401 Ill.Dec. 468 , 50 N.E.3d 610 (quoting People v. Henderson , 2013 IL 114040 , ¶ 33, 370 Ill.Dec. 804 , 989 N.E.2d 192 ).

2019People v. Sutherland , 223 Ill. 2d 187 , 227, 307 Ill.Dec. 524 , 860 N.E.2d 178 (2006). ¶ 22 "The fruit-of-the-poisonous-tree doctrine is an outgrowth of the exclusionary rule providing that 'the fourth amendment violation is deemed the "poisonous tree," and any evidence obtained by exploiting that violation is subject to suppression as the "fruit" of that poisonous tree.' " People v. Burns , 2016 IL 118973 , ¶ 47, 401 Ill.Dec. 468 , 50 N.E.3d 610 (quoting People v. Henderson , 2013 IL 114040 , ¶ 33, 370 Ill.Dec. 804 , 989 N.E.2d 192 ).

12
United States v. Leongreen
scotus · 1984 · cited in 2 Illinois opinions naming this issue, 2018–2019
2 sentences

2019The good-faith exception to the exclusionary rule is a judicially created rule providing that evidence obtained in violation of a defendant’s fourth amendment rights will not be suppressed when “police acted with an ‘ “objectively ‘reasonable good-faith belief’ that their conduct [was] lawful,” ’ or when their conduct involved only simple, isolated negligence.” People v. LeFlore, 2015 IL 116799 , ¶ 24 (quoting United States v. Katzin, 769 F.3d 163, 171 (3d Cir. 2014), quoting Davis v. United States, 564 U.S. 229, 238 (2011), quoting United States v. Leon, 468 U.S. 897, 909 (1984)). ¶ 36 This “

2018The good-faith exception to the exclusionary rule is a judicially created rule providing that evidence obtained in violation of a defendant's fourth amendment rights will not be suppressed when "police acted with an " 'objectively 'reasonable good-faith belief' that their conduct [was] lawful,' " or when their conduct involved only simple, isolated negligence." People v. LeFlore , 2015 IL 116799 , ¶ 24, 392 Ill.Dec. 467 , 32 N.E.3d 1043 (quoting United States v. Katzin , 769 F.3d 163 , 171 (2014), quoting Davis v. United States , 564 U.S. 229 , 238, 131 S.Ct. 2419 , 180 L.Ed.2d 285 (2011), quo

12
United States v. Harry Katzingreen
ca3 · 2014 · cited in 2 Illinois opinions naming this issue, 2018–2019
2 sentences

2019The good-faith exception to the exclusionary rule is a judicially created rule providing that evidence obtained in violation of a defendant’s fourth amendment rights will not be suppressed when “police acted with an ‘ “objectively ‘reasonable good-faith belief’ that their conduct [was] lawful,” ’ or when their conduct involved only simple, isolated negligence.” People v. LeFlore, 2015 IL 116799 , ¶ 24 (quoting United States v. Katzin, 769 F.3d 163, 171 (3d Cir. 2014), quoting Davis v. United States, 564 U.S. 229, 238 (2011), quoting United States v. Leon, 468 U.S. 897, 909 (1984)). ¶ 36 This “

2018The good-faith exception to the exclusionary rule is a judicially created rule providing that evidence obtained in violation of a defendant's fourth amendment rights will not be suppressed when "police acted with an " 'objectively 'reasonable good-faith belief' that their conduct [was] lawful,' " or when their conduct involved only simple, isolated negligence." People v. LeFlore , 2015 IL 116799 , ¶ 24, 392 Ill.Dec. 467 , 32 N.E.3d 1043 (quoting United States v. Katzin , 769 F.3d 163 , 171 (2014), quoting Davis v. United States , 564 U.S. 229 , 238, 131 S.Ct. 2419 , 180 L.Ed.2d 285 (2011), quo

12
People v. Sorensongreen
ill · 2001 · cited in 1 Illinois opinions naming this issue, 2023–2023
1 sentence

2023People v. Bonilla, 2018 IL 122484 , ¶ 35. ¶ 29 “Reasonableness under the fourth amendment generally requires a warrant supported by probable cause.” People v. Sorenson, 196 Ill. 2d 425, 432 (2001).

11
People v. McCauleygreen
ill · 1994 · cited in 1 Illinois opinions naming this issue, 2003–2003
2 sentences

2003People v. McCauley, 163 Ill. 2d 414, 448 , 645 N.E.2d 923, 940 (1994).

2003People v. McCauley, 163 Ill. 2d 414, 448 , 645 N.E.2d 923, 940 (1994).

11
People v. Santanagreen
illappct · 1984 · cited in 1 Illinois opinions naming this issue, 2003–2003
2 sentences

2003See People v. Santana, 121 Ill.

2003See People v. Santana , 121 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 (8)

CaseCitedYears
People v. LeFlore green
ill · 2015
2 sentences

2019The good-faith exception to the exclusionary rule is a judicially created rule providing that evidence obtained in violation of a defendant’s fourth amendment rights will not be suppressed when “police acted with an ‘ “objectively ‘reasonable good-faith belief’ that their conduct [was] lawful,” ’ or when their conduct involved only simple, isolated negligence.” People v. LeFlore, 2015 IL 116799 , ¶ 24 (quoting United States v. Katzin, 769 F.3d 163, 171 (3d Cir. 2014), quoting Davis v. United States, 564 U.S. 229, 238 (2011), quoting United States v. Leon, 468 U.S. 897, 909 (1984)). ¶ 36 This “

2019However, " '[t]he mere fact of a fourth amendment violation does not mean that exclusion necessarily follows' because there 'is no constitutional right to have the evidence resulting from an illegal search or seizure suppressed at trial.' " Id. ¶ 51 (quoting LeFlore , 2015 IL 116799 , ¶ 22, 392 Ill.Dec. 467 , 32 N.E.3d 1043 ).

42018–2019
People v. Bernard neutral
illappct · 2015
2 sentences

2015“The fruit-of-the-poisonous-tree doctrine is an outgrowth of the exclusionary rule.” Id. (citing Henderson, 2013 IL 114040, ¶ 33 ).

2015“The fruit-of-the-poisonous-tree doctrine is an outgrowth of the exclusionary rule.” Id. (citing Henderson, 2013 IL 114040, ¶ 33 ).

32015–2015
People v. Bonilla green
ill · 2018
1 sentence

2023People v. Bonilla, 2018 IL 122484 , ¶ 35. ¶ 29 “Reasonableness under the fourth amendment generally requires a warrant supported by probable cause.” People v. Sorenson, 196 Ill. 2d 425, 432 (2001).

12023–2023
Strickland v. Washington green
scotus · 1984
1 sentence

2020For a claim of ineffective assistance of counsel, a defendant must satisfy the two- pronged test set forth in Strickland v. Washington, 466 U.S. 668 (1984).

12020–2020
People v. Montes green
illappct · 2020
2 sentences

2020We affirm. 2020 IL App (2d) 180565 ¶2 I.

2020Defendant then proceeds to argue that his - 12 - 2020 IL App (2d) 180565 unconstitutional arrest vitiated his consent to search his home and requires suppression of evidence found therein, under the fruit-of-the-poisonous-tree doctrine. ¶ 36 The State’s initial reply is that defendant failed to make a prima facie case on his motion to suppress, because defendant testified that the officers had a warrant to arrest him.

12020–2020
The PEOPLE v. Abrams green
ill · 1971
2 sentences

2003Abrams, 48 Ill. 2d at 455 , 271 N.E.2d at 43 .

2003Abrams, 48 Ill. 2d at 455 , 271 N.E.2d at 43 .

12003–2003
People v. Dickerson green
illappct · 1979
1 sentence

1986App. 3d 825, 828 , 387 N.E.2d 806 ), neither is the fruit-of-the-poisonous-tree doctrine applicable to all evidence discovered in an illegal search (Wong Sun v. United States (1963), 371 U.S. 471, 487-88 , 9 L.

11986–1986
Silverthorne Lumber Co. v. United States green
scotus · 1920
2 sentences

1972In applying the fruit-of-the-poisonous-tree doctrine (Silverthorne Lumber Co. v. United States, 251 U.S. 385 , 64 L.Ed. 319 , 40 S.Ct. 182 ; Wong Sun v. United States, 371 U.S. 471 , 9 L.Ed.2d 441 , 83 S.Ct. 407 ), which Holice Black now asserts, the courts have held that the burden is on the accused in the first instance to prove that the search and seizure was constitutionally impermissible.

1972In applying the fruit-of-the-poisonous-tree doctrine (Silverthorne Lumber Co. v. United States, 251 U.S. 385 , 64 L.Ed. 319 , 40 S.Ct. 182 ; Wong Sun v. United States, 371 U.S. 471 , 9 L.Ed.2d 441 , 83 S.Ct. 407 ), which Holice Black now asserts, the courts have held that the burden is on the accused in the first instance to prove that the search and seizure was constitutionally impermissible.

11972–1972

Statutes the citing opinions construe

IL § 720 ILCS 5/31-4 (5) IL § 720 ILCS 550/4 (5) IL § 720 ILCS 550/5 (5) IL § 720 ILCS 5/31-1 (4) IL § 725 ILCS 5/107-14 (4) IL § 725 ILCS 5/114-12 (4) IL § 720 ILCS 5/24-1.1 (3) IL § 720 ILCS 5/33A-2 (3) IL § 720 ILCS 5/7-7 (3) IL § 720 ILCS 570/401 (3) IL § 725 ILCS 5/108-1.01 (3) IL § 725 ILCS 5/122-1 (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

IL 23 (1972–2023) TX 15 (1993–2025) ND 14 (1980–2023) NJ 8 (2000–2021) MA 6 (1981–2025) MN 5 (1984–2025) AR 5 (2009–2022) IA 4 (2014–2020) NY 4 (1967–1986) WA 3 (2003–2013) PA 3 (2004–2017) KS 3 (1978–1984) MD 3 (1975–1979) AL 3 (1986–2000) VT 3 (2007–2008) MI 3 (1978–2025) CO 3 (2010–2021) DC 2 (2000–2017) KY 2 (2014–2024) CA 2 (1969–2000) RI 2 (1981–2011) OR 2 (2025–2025) MO 2 (1973–1978) MS 2 (2012–2026) ME 2 (1980–1991)

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.

← Caselaw search · G Cite Topics · Brief Check