23 Illinois opinions name it 2 courts 1974–2026 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.
| Case | Followed | Cited |
|---|---|---|
People v. Weargreen2 sentences2019People v. Eichelberger , 91 Ill. 2d 359 , 369, 63 Ill.Dec. 402 , 438 N.E.2d 140 (1982) ; see also Wear , 229 Ill. 2d at 571 , 323 Ill.Dec. 359 , 893 N.E.2d 631 (noting an officer's warrantless nonconsensual entry into the defendant's residence was excused under doctrine of hot pursuit, where at the very least the officer had probable cause to arrest at the threshold of the defendant's home). 2019People v. Eichelberger , 91 Ill. 2d 359 , 369, 63 Ill.Dec. 402 , 438 N.E.2d 140 (1982) ; see also Wear , 229 Ill. 2d at 571 , 323 Ill.Dec. 359 , 893 N.E.2d 631 (noting an officer's warrantless nonconsensual entry into the defendant's residence was excused under doctrine of hot pursuit, where at the very least the officer had probable cause to arrest at the threshold of the defendant's home). | 5 | 5 |
People v. Eichelbergergreen2 sentences2019People v. Eichelberger , 91 Ill. 2d 359 , 369, 63 Ill.Dec. 402 , 438 N.E.2d 140 (1982) ; see also Wear , 229 Ill. 2d at 571 , 323 Ill.Dec. 359 , 893 N.E.2d 631 (noting an officer's warrantless nonconsensual entry into the defendant's residence was excused under doctrine of hot pursuit, where at the very least the officer had probable cause to arrest at the threshold of the defendant's home). 2019People v. Eichelberger , 91 Ill. 2d 359 , 369, 63 Ill.Dec. 402 , 438 N.E.2d 140 (1982) ; see also Wear , 229 Ill. 2d at 571 , 323 Ill.Dec. 359 , 893 N.E.2d 631 (noting an officer's warrantless nonconsensual entry into the defendant's residence was excused under doctrine of hot pursuit, where at the very least the officer had probable cause to arrest at the threshold of the defendant's home). | 2 | 3 |
United States v. Santanagreen2 sentences2026Quite simply, “a suspect may not defeat an arrest which has been set in motion in a public place *** by the expedient of escaping to a private place.” United States v. Santana, 427 U.S. 38, 43 (1976). ¶ 59 The applicability of the hot-pursuit doctrine to this case is unclear to us. 2021Second, the facts strain the hot pursuit doctrine, as contemplated by United States v. Santana, 427 U.S. 38 (1976), to its maximum. | 1 | 6 |
People v. Davisgreen1 sentence2026Pursuant to this doctrine, “police also may enter a private residence without a warrant to effectuate the arrest of a fleeing suspect of whom the police are in ‘hot pursuit.’ ” People v. Davis, 398 Ill. | 1 | 1 |
Payton v. New Yorkgreen2 sentences2008In the case at bar, the majority determines that the circumstances in this case constitute "hot pursuit" and then concludes that the exigent-circumstances requirement for an officer's warrantless, nonconsensual entry into private premises ( Payton v. New York, 445 U.S. 573, 583-90 , 100 S.Ct. 1371, 1378-82 , 63 L.Ed.2d 639, 649-53 (1980)) was satisfied. 229 Ill.2d at 571 , 323 Ill.Dec. at 374 , 893 N.E.2d at 646 ("[Dawdy's] warrantless, nonconsensual entry into Foiles' residence was excused under the doctrine of hot pursuit"). 2008In the case at bar, the majority determines that the circumstances in this case constitute "hot pursuit" and then concludes that the exigent-circumstances requirement for an officer's warrantless, nonconsensual entry into private premises ( Payton v. New York, 445 U.S. 573, 583-90 , 100 S.Ct. 1371, 1378-82 , 63 L.Ed.2d 639, 649-53 (1980)) was satisfied. 229 Ill.2d at 571 , 323 Ill.Dec. at 374 , 893 N.E.2d at 646 ("[Dawdy's] warrantless, nonconsensual entry into Foiles' residence was excused under the doctrine of hot pursuit"). | 1 | 1 |
People v. Yatesgreen2 sentences1985These factors are: 551, 553, 432 N.E.2d 1200 ; see also People v. Yates (1983), 98 Ill. 2d 502, 515 , 456 N.E.2d 1369 .) “(1) [T]he time period between the commission of the crime and the arrest creates a need for prompt action or falls within the ‘spirit’ of the hot pursuit exception; (2) there was a deliberate or unjustified delay by the police during which time a warrant could have been obtained; (3) the suspect was armed or exhibited some sign of a violent character; (4) the officers were acting on a ‘clear showing’ of probable cause; (5) defendant was clearly identified as the offender; ( 1985These factors are: 551, 553, 432 N.E.2d 1200 ; see also People v. Yates (1983), 98 Ill. 2d 502, 515 , 456 N.E.2d 1369 .) “(1) [T]he time period between the commission of the crime and the arrest creates a need for prompt action or falls within the ‘spirit’ of the hot pursuit exception; (2) there was a deliberate or unjustified delay by the police during which time a warrant could have been obtained; (3) the suspect was armed or exhibited some sign of a violent character; (4) the officers were acting on a ‘clear showing’ of probable cause; (5) defendant was clearly identified as the offender; ( | 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. Abney
green
2 sentences1997In People v. Abney, 81 Ill.2d 159, 169-71 , 41 Ill.Dec. 45 , 407 N.E.2d 543 (1980), our supreme court noted some exigent circumstances that may excuse the failure to obtain a warrant: (1) the recentness of the offense and the need for prompt action, such as under the hot-pursuit doctrine; (2) the absence of deliberate or unjustified delay by officers during which a warrant could have been obtained; or (3) an armed suspect who had exhibited signs of violence. 1997In People v. Abney, 81 Ill. 2d 159 , 169-71 (1980), our supreme court noted some exigent circumstances that may excuse the failure to obtain a warrant: (1) the recentness of the offense and the need for prompt action, such as under the hot-pursuit doctrine; (2) the absence of deliberate or unjustified delay by officers during which a warrant could have been obtained; or (3) an armed suspect who had exhibited signs of violence. | 5 | 1981–1997 |
United States v. Watson
green
2 sentences2010Under the hot-pursuit doctrine, “a suspect may not defeat an arrest which has been set in motion in a public place, and is therefore proper under [United States v. Watson, 423 U.S. 411 , 46 L. 2010Under the hot-pursuit doctrine, “a suspect may not defeat an arrest which has been set in motion in a public place, and is therefore proper under [United States v. Watson, 423 U.S. 411 , 46 L. | 2 | 2010–2010 |
People v. Lagle
green
2 sentences2007App. 3d at 955 , 558 N.E.2d at 519 , in which the Fifth District disagreed with the State’s contention "that 'hot pursuit' [was] an exception to the warrant requirement separate and distinct from the exigent[-]circumstances exception." The Fifth District stated: "The cases do not discuss a separate hot pursuit exception to the warrant requirement, but discuss it within the context of discussing exigent circumstances. 2007App. 3d at 955 , 558 N.E.2d at 519 , in which the Fifth District disagreed with the State’s contention “that ‘hot pursuit’ [was] an exception to the warrant requirement separate and distinct from the exigent[-] circumstances exception.” The Fifth District stated: “The cases do not discuss a separate hot pursuit exception to the warrant requirement, but discuss it within the context of discussing exigent circumstances. | 2 | 2007–2007 |
People v. Winters
green
2 sentences2005Citing People v. Winters, 97 Ill. 2d 151 , 454 N.E.2d 299 (1983), the court concluded that no search warrant was needed to arrest defendant because the arrest was based upon the hot pursuit exception. 2005Citing People v. Winters, 97 Ill. 2d 151 , 454 N.E.2d 299 (1983), the court concluded that no search warrant was needed to arrest defendant because the arrest was based upon the hot pursuit exception. | 2 | 2005–2005 |
People v. Tillman
green
1 sentence2026Id. at 198 . | 1 | 2026–2026 |
California v. Ciraolo
green
1 sentence2021Thus, under certain circumstances, a private area within the curtilage of the home may be deemed “public” for purposes of the hot pursuit doctrine, as we saw in Santana. ¶ 24 In this case, defendant’s backyard, albeit fenced-in, did not “preclude [the] officer’s observations from a public vantage point where [they had] a right to be and which render[ed] the activities clearly visible.” See Ciraolo, 476 U.S. at 213 . | 1 | 2021–2021 |
People v. Abney
green
1 sentence1997In People v. Abney, 81 Ill.2d 159, 169-71 , 41 Ill.Dec. 45 , 407 N.E.2d 543 (1980), our supreme court noted some exigent circumstances that may excuse the failure to obtain a warrant: (1) the recentness of the offense and the need for prompt action, such as under the hot-pursuit doctrine; (2) the absence of deliberate or unjustified delay by officers during which a warrant could have been obtained; or (3) an armed suspect who had exhibited signs of violence. | 1 | 1997–1997 |
People v. Grant
neutral
1 sentence1985These factors are: 551, 553, 432 N.E.2d 1200 ; see also People v. Yates (1983), 98 Ill. 2d 502, 515 , 456 N.E.2d 1369 .) “(1) [T]he time period between the commission of the crime and the arrest creates a need for prompt action or falls within the ‘spirit’ of the hot pursuit exception; (2) there was a deliberate or unjustified delay by the police during which time a warrant could have been obtained; (3) the suspect was armed or exhibited some sign of a violent character; (4) the officers were acting on a ‘clear showing’ of probable cause; (5) defendant was clearly identified as the offender; ( | 1 | 1985–1985 |
People v. Hart
green
1 sentence1981(People v. Hart (1980), 88 Ill. | 1 | 1981–1981 |
Taylor v. City of Berwyn
neutral
2 sentences1974(Kindred v. Stitt (1869), 51 Ill. 401 ; Taylor v. City of Berwyn (1938), 297 Ill.App. 417 , 17 N.E.2d 1007 .) The hot-pursuit doctrine is also applicable to a police officer of another State entering the territorial boundaries of this State. 1974(Kindred v. Stitt (1869), 51 Ill. 401 ; Taylor v. City of Berwyn (1938), 297 Ill.App. 417 , 17 N.E.2d 1007 .) The hot-pursuit doctrine is also applicable to a police officer of another State entering the territorial boundaries of this State. | 1 | 1974–1974 |
Kindred v. Stitt
green
2 sentences1974(Kindred v. Stitt (1869), 51 Ill. 401 ; Taylor v. City of Berwyn (1938), 297 Ill.App. 417 , 17 N.E.2d 1007 .) The hot-pursuit doctrine is also applicable to a police officer of another State entering the territorial boundaries of this State. 1974(Kindred v. Stitt (1869), 51 Ill. 401 ; Taylor v. City of Berwyn (1938), 297 Ill.App. 417 , 17 N.E.2d 1007 .) The hot-pursuit doctrine is also applicable to a police officer of another State entering the territorial boundaries of this State. | 1 | 1974–1974 |
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.