chain of custody challenge (Illinois) · Go Syfert
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chain of custody challenge in Illinois

22 Illinois opinions name it 1 courts 1991–2023 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 (12)

CaseFollowedCited
People v. Jonesgreen
illappct · 2002 · cited in 5 Illinois opinions naming this issue, 2007–2008
2 sentences

2008App. 3d 470, 478 (2006) (relying on Johnson and Travis, finding that the defendant’s motion, which simply stated that the evidence to be tested had been in the continuous possession of law enforcement agencies “is facially sufficient with respect to the chain-of-custody requirement”); cf Jones, 334 Ill.

2008App. 3d 470, 478 (2006) (relying on Johnson and Travis, finding that the defendant’s motion, which simply stated that the evidence to be tested had been in the continuous possession of law enforcement agencies “is facially sufficient with respect to the chain-of-custody requirement”); cf. Jones, 334 Ill.

55
People v. Banksgreen
illappct · 2016 · cited in 4 Illinois opinions naming this issue, 2017–2018
2 sentences

2018A chain-of-custody challenge can be reviewed for plain error only "in the rare case" of "a complete breakdown in the chain." Banks , 2016 IL App (1st) 131009 , ¶ 68, 409 Ill.Dec. 230 , 67 N.E.3d 442 ; People v. Alsup , 241 Ill. 2d 266 , 275, 349 Ill.Dec. 921 , 948 N.E.2d 24 (2011) (plain error occurs " '[w]hen there is a complete failure of proof , there is no link between the substance tested by the chemist and the substance recovered at the time of defendant's arrest' " (emphases in original) (quoting Woods , 214 Ill. 2d at 472 , 293 Ill.Dec. 277 , 828 N.E.2d 247 ) ).

2018A chain-of-custody challenge can be reviewed for plain error only "in the rare case" of "a complete breakdown in the chain." Banks , 2016 IL App (1st) 131009 , ¶ 68, 409 Ill.Dec. 230 , 67 N.E.3d 442 ; People v. Alsup , 241 Ill. 2d 266 , 275, 349 Ill.Dec. 921 , 948 N.E.2d 24 (2011) (plain error occurs " '[w]hen there is a complete failure of proof , there is no link between the substance tested by the chemist and the substance recovered at the time of defendant's arrest' " (emphases in original) (quoting Woods , 214 Ill. 2d at 472 , 293 Ill.Dec. 277 , 828 N.E.2d 247 ) ).

34
People v. Gibsongreen
illappct · 1997 · cited in 3 Illinois opinions naming this issue, 2007–2007
2 sentences

2007People v. Gibson, 287 Ill.

2007People v. Gibson, 287 Ill.

33
People v. Woodsgreen
ill · 2005 · cited in 6 Illinois opinions naming this issue, 2016–2022
2 sentences

2018A chain-of-custody challenge can be reviewed for plain error only "in the rare case" of "a complete breakdown in the chain." Banks , 2016 IL App (1st) 131009 , ¶ 68, 409 Ill.Dec. 230 , 67 N.E.3d 442 ; People v. Alsup , 241 Ill. 2d 266 , 275, 349 Ill.Dec. 921 , 948 N.E.2d 24 (2011) (plain error occurs " '[w]hen there is a complete failure of proof , there is no link between the substance tested by the chemist and the substance recovered at the time of defendant's arrest' " (emphases in original) (quoting Woods , 214 Ill. 2d at 472 , 293 Ill.Dec. 277 , 828 N.E.2d 247 ) ).

2018A chain-of-custody challenge can be reviewed for plain error only "in the rare case" of "a complete breakdown in the chain." Banks , 2016 IL App (1st) 131009 , ¶ 68, 409 Ill.Dec. 230 , 67 N.E.3d 442 ; People v. Alsup , 241 Ill. 2d 266 , 275, 349 Ill.Dec. 921 , 948 N.E.2d 24 (2011) (plain error occurs " '[w]hen there is a complete failure of proof , there is no link between the substance tested by the chemist and the substance recovered at the time of defendant's arrest' " (emphases in original) (quoting Woods , 214 Ill. 2d at 472 , 293 Ill.Dec. 277 , 828 N.E.2d 247 ) ).

26
People v. Smithgreen
illappct · 2014 · cited in 3 Illinois opinions naming this issue, 2015–2023
2 sentences

2023We determine whether the requested testing has the potential to produce new, non- cumulative evidence materially relevant to Galloway’s claim of actual innocence. ¶ 46 “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 .

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)).

23
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. Gholstongreen
illappct · 1984 · cited in 2 Illinois opinions naming this issue, 2013–2013
2 sentences

2013In People v. Gholston, 124 Ill.

2013In People v. Gholston, 124 Ill.

22
People v. Schutzgreen
illappct · 2003 · cited in 2 Illinois opinions naming this issue, 2006–2006
2 sentences

2006People v. Schutz, 344 Ill.

2006People v. Schutz, 344 Ill.

22
People v. Alexandergreen
illappct · 1985 · cited in 2 Illinois opinions naming this issue, 2006–2006
2 sentences

2006See People v. Alexander, 136 Ill.

2006See People v. Alexander, 136 Ill.

22
People v. Alsupgreen
ill · 2011 · cited in 3 Illinois opinions naming this issue, 2018–2022
2 sentences

2022Specifically, he is arguing that there was insufficient evidence that the videos produced at trial were the same videos as the ones recovered from the hard drive of his computer. ¶ 38 However, the chain of custody principle “does not serve as a challenge to the sufficiency of evidence to support a conviction and is not exempt from forfeiture.” Alsup, 241 Ill. 2d at 275 .

2018A chain-of-custody challenge can be reviewed for plain error only "in the rare case" of "a complete breakdown in the chain." Banks , 2016 IL App (1st) 131009 , ¶ 68, 409 Ill.Dec. 230 , 67 N.E.3d 442 ; People v. Alsup , 241 Ill. 2d 266 , 275, 349 Ill.Dec. 921 , 948 N.E.2d 24 (2011) (plain error occurs " '[w]hen there is a complete failure of proof , there is no link between the substance tested by the chemist and the substance recovered at the time of defendant's arrest' " (emphases in original) (quoting Woods , 214 Ill. 2d at 472 , 293 Ill.Dec. 277 , 828 N.E.2d 247 ) ).

13
People v. Johnsongreen
ill · 2002 · cited in 1 Illinois opinions naming this issue, 2021–2021
1 sentence

2021People v. Kines, 2015 IL App (2d) 140518, ¶ 29 (citing People v. Johnson, 205 Ill. 2d 381, 393 (2002)); People v. Bailey, 386 Ill. - 12 - No. 1-18-0921 App. 3d 68, 74-75 (2008) (and cases cited therein).

11
People v. Kinesgreen
illappct · 2015 · cited in 1 Illinois opinions naming this issue, 2021–2021
1 sentence

2021People v. Kines, 2015 IL App (2d) 140518, ¶ 29 (citing People v. Johnson, 205 Ill. 2d 381, 393 (2002)); People v. Bailey, 386 Ill. - 12 - No. 1-18-0921 App. 3d 68, 74-75 (2008) (and cases cited therein).

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 (3)

CaseCitedYears
People v. Lach green
illappct · 1998
2 sentences

2017Morris, 2013 IL App (1st) 111251, ¶ 91 ; Lach, 302 Ill.

2017Morris, 2013 IL App (1st) 111251, ¶ 91 ; Lach, 302 Ill.

22017–2017
People v. Morris green
illappct · 2013
2 sentences

2017Morris, 2013 IL App (1st) 111251, ¶ 91 ; Lach, 302 Ill.

2017Morris, 2013 IL App (1st) 111251, ¶ 91 ; Lach, 302 Ill.

22017–2017
People v. Vazquez green
illappct · 1989
1 sentence

1991Vazquez, 180 Ill.

11991–1991

Statutes the citing opinions construe

IL § 725 ILCS 5/116-3 (8) IL § 725 ILCS 5/122-1 (4) IL § 720 ILCS 570/401 (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 47 (1972–2023) TN 40 (1999–2026) VA 34 (1984–2025) GA 28 (1986–2021) IL 22 (1991–2023) LA 20 (1988–2014) SC 13 (2004–2025) OK 13 (1984–2010) CA 11 (2001–2023) AL 9 (1994–2014) MO 7 (1975–1992) TX 7 (2010–2024) MN 6 (1976–2016) NY 5 (1977–2023) WA 5 (1996–2024) DE 4 (1987–2020) ME 4 (1976–2014) ND 4 (1979–2005) AR 4 (1995–2022) DC 3 (1994–2016) CO 3 (1999–2021) WV 2 (1977–1987) PA 2 (2008–2019)

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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