invalid waiver (Illinois) · Go Syfert
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invalid waiver in Illinois

22 Illinois opinions name it 2 courts 1983–2024 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 (9)

CaseFollowedCited
People v. Scottgreen
ill · 1999 · cited in 2 Illinois opinions naming this issue, 2008–2008
2 sentences

2008Scott, 186 Ill. 2d at 284 (holding that a written waiver alone is an invalid waiver).

2008Scott, 186 Ill. 2d at 284 (holding that a written waiver alone is an invalid waiver).

22
Hernandez v. Fahnergreen
illappct · 1985 · cited in 2 Illinois opinions naming this issue, 2004–2004
2 sentences

2004App. 3d at 1047-48 (agency’s adoption of a policy whereby it adjudicated grain quality disputes among producers, dealers, and warehouses constituted an invalid rule and, therefore, complaining party was entitled to reasonable attorney fees); Hernandez v. Fahner, 135 Ill.

2004App. 3d at 1047-48 (agency's adoption of a policy whereby it adjudicated grain quality disputes among producers, dealers, and warehouses constituted an invalid rule and, therefore, complaining party was entitled to reasonable attorney fees); Hernandez v. Fahner , 135 Ill.

22
United States v. Gonzalez-Lopezgreen
scotus · 2006 · cited in 1 Illinois opinions naming this issue, 2024–2024
2 sentences

2024See United States v. Gonzalez-Lopez, 548 U.S. 140, 149 (2006) (“Such [structural] errors include denial of counsel ***.” (citing Gideon, 372 U.S. 335 ); United States v. Allen, 895 F.2d 1577, 1580 (10th Cir. 1990) (“Acceptance of an invalid waiver in violation of a defendant’s Sixth Amendment rights necessarily leaves him entirely without the assistance of counsel at trial.” (Internal quotation marks omitted.)).

2024See Allen, 895 F.2d at 1580 (“Acceptance of an invalid waiver in violation of a defendant’s Sixth Amendment rights necessarily leaves him entirely without the assistance of counsel at trial.” (Internal quotation marks omitted.)); Gonzalez-Lopez, 548 U.S. at 149 .

11
Sullivan v. Louisianagreen
scotus · 1993 · cited in 1 Illinois opinions naming this issue, 2024–2024
1 sentence

2024In Gonzalez-Lopez, 548 U.S. at 150 , the United States Supreme Court held that the “erroneous deprivation of the right to counsel of choice, ‘with consequences that are necessarily unquantifiable and indeterminate, unquestionably qualifies as “structural error.” ’ ” (quoting Sullivan v. Louisiana, 508 U.S. 275, 282 (1993)). ¶ 131 I would find that the circuit court deprived Ratliff of counsel by failing to admonish Ratliff about his right to counsel pursuant to Rule 401(a), thereby causing Ratliff to be left without counsel at critical stages of the criminal proceedings: during the jury select

11
Gideon v. Wainwrightgreen
scotus · 1963 · cited in 1 Illinois opinions naming this issue, 2024–2024
1 sentence

2024See United States v. Gonzalez-Lopez, 548 U.S. 140, 149 (2006) (“Such [structural] errors include denial of counsel ***.” (citing Gideon, 372 U.S. 335 ); United States v. Allen, 895 F.2d 1577, 1580 (10th Cir. 1990) (“Acceptance of an invalid waiver in violation of a defendant’s Sixth Amendment rights necessarily leaves him entirely without the assistance of counsel at trial.” (Internal quotation marks omitted.)).

11
United States v. Lewis D. Allengreen
ca10 · 1990 · cited in 1 Illinois opinions naming this issue, 2024–2024
2 sentences

2024See United States v. Gonzalez-Lopez, 548 U.S. 140, 149 (2006) (“Such [structural] errors include denial of counsel ***.” (citing Gideon, 372 U.S. 335 ); United States v. Allen, 895 F.2d 1577, 1580 (10th Cir. 1990) (“Acceptance of an invalid waiver in violation of a defendant’s Sixth Amendment rights necessarily leaves him entirely without the assistance of counsel at trial.” (Internal quotation marks omitted.)).

2024See Allen, 895 F.2d at 1580 (“Acceptance of an invalid waiver in violation of a defendant’s Sixth Amendment rights necessarily leaves him entirely without the assistance of counsel at trial.” (Internal quotation marks omitted.)); Gonzalez-Lopez, 548 U.S. at 149 .

11
People v. Vernongreen
illappct · 2009 · cited in 1 Illinois opinions naming this issue, 2022–2022
1 sentence

2022See People v. 6 Vernon, 396 Ill.

11
In Re RABgreen
ill · 2001 · cited in 1 Illinois opinions naming this issue, 2022–2022
1 sentence

2022Id. at 811 (quoting In re R.A.B., 197 Ill. 2d 358, 363 (2001)).

11
People v. Smithgreen
illappct · 1988 · cited in 1 Illinois opinions naming this issue, 2012–2012
2 sentences

2012Id. at 770 , 146 Ill.Dec. 516 , 558 N.E.2d 479 ; see also People v. Smith, 176 Ill.App.3d 132, 139 , 125 Ill.Dec. 695 , 530 N.E.2d 1104 (1988) ("[A] per se disqualification is based on the invalid presumption that public defenders are unable to subordinate office allegiances to the foremost obligation owed to their clients."). ¶ 40 Here, the Conflicts II unit of the public defender's office represented the mother in a previous juvenile proceeding that was closed in 2003.

2012Id. at 770 , 146 Ill.Dec. 516 , 558 N.E.2d 479 ; see also People v. Smith, 176 Ill.App.3d 132, 139 , 125 Ill.Dec. 695 , 530 N.E.2d 1104 (1988) ("[A] per se disqualification is based on the invalid presumption that public defenders are unable to subordinate office allegiances to the foremost obligation owed to their clients."). ¶ 40 Here, the Conflicts II unit of the public defender's office represented the mother in a previous juvenile proceeding that was closed in 2003.

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 (12)

CaseCitedYears
People v. Lewis green
ill · 2009
2 sentences

2019However, “[t]he first step of plain-error review is to determine whether any error occurred.” Id.

2018However, "[t]he first step of plain-error review is to determine whether any error occurred." Id.

42016–2019
Sutton v. Edgar green
illappct · 1986
2 sentences

2005Sutton , 147 Ill.

2005Sutton, 147 Ill.

22005–2005
Strickland v. Washington green
scotus · 1984
2 sentences

2000Although pursuing an invalid defense may be proper strategy when the defendant consents to the strategy, defendant argues that the record here does not show his consent. • A defendant raising an ineffective assistance of counsel claim must meet the two-part test of Strickland v. Washington, 466 U.S. 668 , 80 L.

2000Although pursuing an invalid defense may be proper strategy when the defendant consents to the strategy, defendant argues that the record here does not show his consent. • A defendant raising an ineffective assistance of counsel claim must meet the two-part test of Strickland v. Washington, 466 U.S. 668 , 80 L.

22000–2000
People v. Owens green
illappct · 2002
1 sentence

2022Id. at 811 (quoting In re R.A.B., 197 Ill. 2d 358, 363 (2001)).

12022–2022
People v. Vaughn green
illappct · 1990
2 sentences

2012Id. at 770 , 146 Ill.Dec. 516 , 558 N.E.2d 479 ; see also People v. Smith, 176 Ill.App.3d 132, 139 , 125 Ill.Dec. 695 , 530 N.E.2d 1104 (1988) ("[A] per se disqualification is based on the invalid presumption that public defenders are unable to subordinate office allegiances to the foremost obligation owed to their clients."). ¶ 40 Here, the Conflicts II unit of the public defender's office represented the mother in a previous juvenile proceeding that was closed in 2003.

2012Id. at 770 , 146 Ill.Dec. 516 , 558 N.E.2d 479 ; see also People v. Smith, 176 Ill.App.3d 132, 139 , 125 Ill.Dec. 695 , 530 N.E.2d 1104 (1988) ("[A] per se disqualification is based on the invalid presumption that public defenders are unable to subordinate office allegiances to the foremost obligation owed to their clients."). ¶ 40 Here, the Conflicts II unit of the public defender's office represented the mother in a previous juvenile proceeding that was closed in 2003.

12012–2012
People v. Matthews green
illappct · 1999
2 sentences

2005App. 3d 415 , 710 N.E.2d 524 . 1 In this case, the trial court relied on Chandler in denying defendant’s motion for a new trial on the ground of an invalid waiver of her right to a 12-person jury.

2005Matthews, 304 Ill.App.3d 415 , 237 Ill.Dec. 894 , 710 N.E.2d 524 . [1] *620 In this case, the trial court relied on Chandler in denying defendant's motion for a new trial on the ground of an invalid waiver of her right to a 12-person jury.

12005–2005
People v. Solis green
illappct · 1991
1 sentence

1993This argument is based upon the invalid presumption that death is not a form of bodily harm and that one may intend to kill another without intending to inflict bodily harm.” Solis, 216 Ill.

11993–1993
Bagwell v. Industrial Commission green
ill · 1983
1 sentence

1990The supreme court also held that Celotex had no duty to resubmit information that it had already furnished and certified as current: “The permit can be denied only if the information was not already submitted and certified as current, and only if without the information the application was insufficient to show compliance with rules of the Board other than those which were invalidated.” ( 94 Ill. 2d at 128 .) No distinction was made between an original operating permit application and a renewal application.

11990–1990
Landfill, Inc. v. Pollution Control Board green
ill · 1979
2 sentences

1989Bio-Medical Laboratories, Inc., 68 Ill. 2d 540 , 370 N.E.2d 223 ; Landfill, Inc. v. Pollution Control Board (1978), 74 Ill. 2d 541 , 387 N.E.2d 258 .

1989Bio-Medical Laboratories, Inc., 68 Ill. 2d 540 , 370 N.E.2d 223 ; Landfill, Inc. v. Pollution Control Board (1978), 74 Ill. 2d 541 , 387 N.E.2d 258 .

11989–1989
Bio-Medical Laboratories, Inc. v. Trainor green
ill · 1977
2 sentences

1989Bio-Medical Laboratories, Inc., 68 Ill. 2d 540 , 370 N.E.2d 223 ; Landfill, Inc. v. Pollution Control Board (1978), 74 Ill. 2d 541 , 387 N.E.2d 258 .

1989Bio-Medical Laboratories, Inc., 68 Ill. 2d 540 , 370 N.E.2d 223 ; Landfill, Inc. v. Pollution Control Board (1978), 74 Ill. 2d 541 , 387 N.E.2d 258 .

11989–1989
People v. Banks green
ill · 1987
2 sentences

1988(Banks, 121 Ill. 2d at 46 , 520 N.E .2d at 622 (Clark, C.J., specially concurring).) The adoption of such an approach, the court reasoned, is necessary because a per se disqualification is based on the invalid presumption that public defenders are unable to subordinate office allegiances to the foremost obligation owed to their clients.

1988Banks, 121 Ill. 2d at 43 , 520 N.E .2d at 620.

11988–1988
United States Steel Corp. v. Pollution Control Board neutral
illappct · 1978
1 sentence

1983The Agency also argues that the reasonableness of Rule 202(b) was established in United States Steel Corp. v. Pollution Control Board (1978), 64 Ill.

11983–1983

Statutes the citing opinions construe

IL § 725 ILCS 5/103-6 (6) IL § 725 ILCS 5/110-14 (5) IL § 725 ILCS 5/115-1 (5) IL § 30 ILCS 105/6z-82 (4) IL § 55 ILCS 5/3-4012 (4) IL § 55 ILCS 5/4-2002 (4) IL § 705 ILCS 105/27.3a (4) IL § 705 ILCS 105/27.3e (4) IL § 730 ILCS 5/5-4.5-30 (4) IL § 625 ILCS 5/11-204 (3) IL § 625 ILCS 5/11-204.1 (3) IL § 725 ILCS 5/101-1 (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

TX 56 (1955–2025) NY 44 (1909–2025) CA 36 (1928–2025) FL 25 (1958–2026) OH 24 (1976–2026) IL 22 (1983–2024) LA 18 (1971–2019) CO 18 (1993–2026) ID 16 (1987–2025) OR 16 (1983–2026) MI 15 (1967–2023) PA 15 (1939–2021) MD 13 (1937–2017) MN 12 (1960–2026) WA 12 (1897–2024) WI 9 (1975–2022) AZ 8 (1935–2024) CT 8 (1993–2022) MO 7 (1915–1998) IN 7 (1976–2023) VA 6 (1852–1998) OK 6 (1933–1985) HI 5 (1973–2018) NV 5 (1998–2025) NJ 5 (1959–2026) AL 5 (1898–2016) SD 4 (2007–2025) TN 4 (1940–2009) MA 4 (1983–2020) VT 3 (1987–2016) WV 3 (1946–2014) ME 3 (1985–2012) IA 3 (1976–2014) AR 2 (1988–2021) MS 2 (2010–2021) KS 2 (1985–2022) NM 2 (2001–2006) NC 2 (1989–1997) KY 2 (1928–1931) AK 2 (1975–1996) NH 2 (1977–2006) ND 2 (2006–2006) GA 2 (1989–2003)

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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