bench trial error (Illinois) · Go Syfert
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bench trial error in Illinois

22 Illinois opinions name it 2 courts 1969–2025 3 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 (7)

CaseFollowedCited
People Ex Rel. Daley v. Joycegreen
ill · 1988 · cited in 2 Illinois opinions naming this issue, 1996–2021
2 sentences

2021Daley v. Joyce, 126 Ill. 2d 209, 221-22 (1988). “[W]aivers [of constitutional rights] must not only be voluntary, but must be ‘ ”knowing, intelligent acts done with sufficient awareness of the relevant circumstances and likely consequences.” ’ ” People v. McClanahan, 191 Ill. 2d 127, 137 (2000) (quoting People v. Johnson, 75 Ill. 2d 180, 187 (1979), quoting Brady v. United States, 397 U.S. 742, 748 (1970)). ¶ 21 The waiver of a bench trial rarely comes up in case law, likely because “a jury trial is the norm for a felony case and a bench trial is the exception.” People v. Powell, 281 Ill.

1996See People ex rel[.] Daley v[.] Joyce, 126 Ill. 2d 209 , 533 N.E.2d [873] (1988).” Defendant also argues that "[d]efense counsel made clear that he had a personal preference for a jury trial and he decided to go forward with the jury trial regardless of the defendant’s wishes.” •1 Although we think defendant’s argument mischaracterizes the record regarding Clifton’s discussion with defendant on the desirability of a jury trial, we choose to address it as if — as defendant claims on appeal — defendant wanted a bench trial all along and Clifton never so informed the court.

22
People v. Powellgreen
illappct · 1996 · cited in 3 Illinois opinions naming this issue, 2013–2025
2 sentences

2025Taking defendant’s allegation as true and liberally construing it in his favor, as we must at this stage, defendant’s allegation sufficiently demonstrates defendant informed defense counsel he wanted a bench trial and defense counsel usurped defendant’s right to waive a jury trial by failing to honor defendant’s wishes. -8- ¶ 27 The State relies on People v. Powell, 281 Ill.

2021Daley v. Joyce, 126 Ill. 2d 209, 221-22 (1988). “[W]aivers [of constitutional rights] must not only be voluntary, but must be ‘ ”knowing, intelligent acts done with sufficient awareness of the relevant circumstances and likely consequences.” ’ ” People v. McClanahan, 191 Ill. 2d 127, 137 (2000) (quoting People v. Johnson, 75 Ill. 2d 180, 187 (1979), quoting Brady v. United States, 397 U.S. 742, 748 (1970)). ¶ 21 The waiver of a bench trial rarely comes up in case law, likely because “a jury trial is the norm for a felony case and a bench trial is the exception.” People v. Powell, 281 Ill.

13
Talmage v. Union Central Life Insurancegreen
illappct · 1942 · cited in 2 Illinois opinions naming this issue, 2008–2009
2 sentences

2009Talmage v. Union Central Life Insurance Co., 315 Ill.App. 623, 642 , 43 N.E.2d 575 (1942).

2009Talmage v. Union Central Life Insurance Co., 315 Ill.App. 623, 642 , 43 N.E.2d 575 (1942).

12
In Re Marriage of Matchengreen
illappct · 2007 · cited in 1 Illinois opinions naming this issue, 2024–2024
1 sentence

2024In re Marriage of Matchen, 372 Ill.

11
People v. Johnsongreen
ill · 1979 · cited in 1 Illinois opinions naming this issue, 2021–2021
1 sentence

2021Daley v. Joyce, 126 Ill. 2d 209, 221-22 (1988). “[W]aivers [of constitutional rights] must not only be voluntary, but must be ‘ ”knowing, intelligent acts done with sufficient awareness of the relevant circumstances and likely consequences.” ’ ” People v. McClanahan, 191 Ill. 2d 127, 137 (2000) (quoting People v. Johnson, 75 Ill. 2d 180, 187 (1979), quoting Brady v. United States, 397 U.S. 742, 748 (1970)). ¶ 21 The waiver of a bench trial rarely comes up in case law, likely because “a jury trial is the norm for a felony case and a bench trial is the exception.” People v. Powell, 281 Ill.

11
People v. McClanahangreen
ill · 2000 · cited in 1 Illinois opinions naming this issue, 2021–2021
1 sentence

2021Daley v. Joyce, 126 Ill. 2d 209, 221-22 (1988). “[W]aivers [of constitutional rights] must not only be voluntary, but must be ‘ ”knowing, intelligent acts done with sufficient awareness of the relevant circumstances and likely consequences.” ’ ” People v. McClanahan, 191 Ill. 2d 127, 137 (2000) (quoting People v. Johnson, 75 Ill. 2d 180, 187 (1979), quoting Brady v. United States, 397 U.S. 742, 748 (1970)). ¶ 21 The waiver of a bench trial rarely comes up in case law, likely because “a jury trial is the norm for a felony case and a bench trial is the exception.” People v. Powell, 281 Ill.

11
Brady v. United Statesgreen
scotus · 1970 · cited in 1 Illinois opinions naming this issue, 2021–2021
1 sentence

2021Daley v. Joyce, 126 Ill. 2d 209, 221-22 (1988). “[W]aivers [of constitutional rights] must not only be voluntary, but must be ‘ ”knowing, intelligent acts done with sufficient awareness of the relevant circumstances and likely consequences.” ’ ” People v. McClanahan, 191 Ill. 2d 127, 137 (2000) (quoting People v. Johnson, 75 Ill. 2d 180, 187 (1979), quoting Brady v. United States, 397 U.S. 742, 748 (1970)). ¶ 21 The waiver of a bench trial rarely comes up in case law, likely because “a jury trial is the norm for a felony case and a bench trial is the exception.” People v. Powell, 281 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 (17)

CaseCitedYears
People v. Zemblidge green
illappct · 1982
2 sentences

2017Downs III resolved the issue arising from the reasonable-doubt question, and we note these circumstances for completeness. -5- 2017 IL App (2d) 121156-C respect to the bench-trial claim: “Counsel adopts in part and amends Defendant’s #11, to wit: ‘On first and second day of trial defendant asked (trial) counsel to dismiss the Jury and instead continue with a Bench Trial, but counsel ignored defendant.’ Defendant acknowledges that once the trial had begun the decision to waive defendant’s jury right reverts to the discretion of the court (People v. Zemblidge, 104 Ill.

2017In submitting defendant’s second amended motion alleging ineffectiveness of trial counsel, Krankel counsel stated with respect to the bench-trial claim: “Counsel adopts in part and amends Defendant’s #11, to wit: ‘On first and second day of trial defendant asked (trial) counsel to dismiss the Jury and instead continue with a Bench Trial, but counsel ignored defendant.’ Defendant acknowledges that once the trial had begun the decision to waive defendant’s jury right reverts to the discretion of the court (People v. Zemblidge, 104 Ill.

22017–2017
Reliable Fire Equipment Co. v. Arredondo green
illappct · 2010
2 sentences

2011A divided panel of the appellate court upheld the circuit court's order. 405 Ill.

2011A divided panel of the appellate court upheld the circuit court’s order. 405 Ill.

22011–2011
In re Marriage of Bernay green
illappct · 2017
1 sentence

2024In re Marriage of Bernay, 2017 IL App (2d) 160583, ¶ 14 . ¶ 21 In a bench trial or a hearing such as the lengthy multi-day proceedings on Scott’s motion, the trial court sits as the trier of fact, hearing the witnesses and reviewing the direct presentation of the evidence, and it is in the best position to make credibility determinations and factual findings.

12024–2024
People v. Kallal green
illappct · 2019
1 sentence

2019As a result, we find no need to expand the supreme court’s bench trial requirement to a jury trial on a defendant’s recovery petition if the jury has been properly instructed on this point of law.” People v. Kallal, 2019 IL App (4th) 180099, ¶ 50 .

12019–2019
People v. Schmitt green
ill · 1989
2 sentences

2018People v. Schmitt , 131 Ill. 2d 128 , 138, 137 Ill.Dec. 12 , 545 N.E.2d 665 (1989).

2018People v. Schmitt , 131 Ill. 2d 128 , 138, 137 Ill.Dec. 12 , 545 N.E.2d 665 (1989).

12018–2018
People v. Rogers green
illappct · 2015
1 sentence

2016Id. ¶ 34 In his initial appointment, Krankel counsel adopted five of defendant’s pro se claims of ineffective assistance, including the general claim, the bench-trial claim, and the alibi claim.

12016–2016
Colgan v. Rae-Ann Electric Co. green
illappct · 1980
1 sentence

1994App. 3d 386, 392 , 414 N.E.2d 1343, 1347 .) Defendant does not argue that the dual trial was error, but only that the award of damages in the bench trial was error.

11994–1994
People v. Shegog green
illappct · 1976
2 sentences

1992App. 3d 615 , 346 N.E.2d 208 , the appellate court found that the trial court improperly admitted an undisclosed statement into evidence in a bench trial in violation of Rule 412 and section 114 — 10.

1992(Shegog, 37 Ill.

11992–1992
People v. Enoch green
ill · 1988
1 sentence

1992Our supreme court, in People v. Enoch (1988), 122 Ill. 2d 176 , clarified the necessity of raising alleged errors in a written, post-trial motion.

11992–1992
People v. Pagan green
ill · 1972
2 sentences

1983(People v. Pagan (1972), 52 Ill. 2d 525 , 288 N.E.2d 102 .) Nothing in the record persuades us that the trial court was influenced by the witness’ race in considering his testimony.

1983(People v. Pagan (1972), 52 Ill. 2d 525 , 288 N.E.2d 102 .) Nothing in the record persuades us that the trial court was influenced by the witness’ race in considering his testimony.

11983–1983
People v. Terranova neutral
illappct · 1977
1 sentence

1979App. 3d 1023, 1027 , 379 N.E.2d 1303 ; People v. Terranova (1977), 49 Ill.

11979–1979
People v. Jenkins neutral
illappct · 1978
2 sentences

1979Although defendant did not raise the issue in her post-trial motion, it has been held that a post-trial motion is not necessary to preserve error in a bench trial when the error has been brought to the attention of the trial court by motion or timely objection, thus" giving the trial court the opportunity to correct the error (People v. Jenkins (1978), 62 Ill.

1979App. 3d 1023, 1027 , 379 N.E.2d 1303 ; People v. Terranova (1977), 49 Ill.

11979–1979
The People v. Hoffman green
ill · 1942
2 sentences

1977(People v. Hoffman (1942), 381 Ill. 460 , 45 N.E.2d 874 .) This court’s Third District has held that a post-trial motion is not necessary to preserve error in a bench trial when the error has been brought to the attention of the trial court by motion or by timely objection, thus, giving the trial court the opportunity to correct the error involved.

1977(People v. Hoffman (1942), 381 Ill. 460 , 45 N.E.2d 874 .) This court’s Third District has held that a post-trial motion is not necessary to preserve error in a bench trial when the error has been brought to the attention of the trial court by motion or by timely objection, thus, giving the trial court the opportunity to correct the error involved.

11977–1977
People v. Guynn green
illappct · 1975
1 sentence

1977People v. Guynn (1975), 33 Ill.

11977–1977
The People v. Gooden green
ill · 1949
2 sentences

1971The cases cited by defendants, People v. Gooden (1949), 403 Ill. 455 , 86 N.E.2d 198 and People v. Botulinski (1943), 383 Ill. 608 , 50 N.E.2d 716 , bear no similarity to the contention urged by defendants.

1971The cases cited by defendants, People v. Gooden (1949), 403 Ill. 455 , 86 N.E.2d 198 and People v. Botulinski (1943), 383 Ill. 608 , 50 N.E.2d 716 , bear no similarity to the contention urged by defendants.

11971–1971
The People v. Botulinski green
ill · 1943
2 sentences

1971The cases cited by defendants, People v. Gooden (1949), 403 Ill. 455 , 86 N.E.2d 198 and People v. Botulinski (1943), 383 Ill. 608 , 50 N.E.2d 716 , bear no similarity to the contention urged by defendants.

1971The cases cited by defendants, People v. Gooden (1949), 403 Ill. 455 , 86 N.E.2d 198 and People v. Botulinski (1943), 383 Ill. 608 , 50 N.E.2d 716 , bear no similarity to the contention urged by defendants.

11971–1971
The People v. Robinson green
ill · 1964
1 sentence

1969People v. Robinson, 30 Ill2d 437, 197 NE2d 45 .

11969–1969

Statutes the citing opinions construe

IL § 720 ILCS 5/9-1 (5)

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 22 (1969–2025) AR 19 (2005–2024) TX 7 (2002–2019) GA 3 (2003–2012) CA 3 (2021–2023) IN 3 (1983–2018) HI 2 (1996–2012) MO 2 (2019–2023) NC 2 (2011–2026) MA 2 (1995–2001)

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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