140 Illinois opinions name it 2 courts 1956–2026 40 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. Bensongreen2 sentences2020See id. at 149 (“The second limitation section 115-11 of the Code places upon the trial court is to direct that the court may exclude from the proceedings only those persons who, in the opinion of the court, do not have a direct interest in the case; the obverse of this means that those -8- persons who do have a direct interest in the case, such as a defendant’s immediate family, may not be excluded.” (Emphases in original.)). ¶ 36 As stated, defendant argues that second-prong plain error occurred in this case. 2019See id. at 149 (“The second limitation section 115-11 of the Code places upon the trial court is to direct that the court may exclude from the proceedings only those persons who, in the opinion of the court, do not have a direct interest in the case; the obverse of this means that those persons who do have a direct interest in the case, such as a defendant’s immediate family, may not be excluded.” (Emphases in original.)). ¶ 36 As stated, defendant argues that second-prong plain error occurred in this case. | 2 | 2 |
People v. Donegangreen2 sentences2017See, e.g., People v. Donegan, 2012 IL App (1st) 102325, ¶ 62 , 974 N.E.2d 352 (acknowledging the trial court’s discretion to limit the number of prior inconsistent statements that may be introduced). ¶ 88 We note that when the trial court conducted a hearing on defendant’s proffers of evidence concerning the January 2013 incident at the Freight House Tavern in Beardstown involving Box, the court was informed regarding what defendant would say about that incident, as well as what the testimony would be of other witnesses whom the State would present. 2017See, e.g., People v. Donegan, 2012 IL App (1st) 102325, ¶ 62 , 974 N.E.2d 352 (acknowledging the trial court’s discretion to limit the number of prior inconsistent statements that may be introduced). ¶ 88 We note that when the trial court conducted a hearing on defendant’s proffers of evidence concerning the January 2013 incident at the Freight House Tavern in Beardstown involving Box, the court was informed regarding what defendant would say about that incident, as well as what the testimony would be of other witnesses whom the State would present. | 2 | 2 |
People v. Taylorgreen2 sentences2012See People v. Taylor, 237 Ill.2d 356, 372 , 341 Ill.Dec. 445 , 930 N.E.2d 959 (2010) (stating that the purpose of a postconviction proceeding is to permit inquiry into constitutional issues involved in the original trial that have not been, and could not have been, adjudicated previously upon direct review). 2012See People v. Taylor, 237 Ill.2d 356, 372 , 341 Ill.Dec. 445 , 930 N.E.2d 959 (2010) (stating that the purpose of a postconviction proceeding is to permit inquiry into constitutional issues involved in the original trial that have not been, and could not have been, adjudicated previously upon direct review). | 2 | 2 |
People v. Kirkpatrickgreen2 sentences2026Thus, Justice McLaren opined, “the entire issue is not justiciable and need not be addressed in this appeal,” because “[o]nce the State moved to dismiss on the merits and did not attack or move to dismiss on the issue of the lack of a notarized affidavit, the issue of the need for a proper affidavit, or for verification by any means, became moot.” (Emphasis in original.) 2011 IL App (2d) 100031, ¶ 25 . ¶ 14 The State points out that in People v. Kirkpatrick, 2012 IL App (2d) 100898, ¶ 27 , the court declined to follow Nitz, instead holding that “[o]nce the State moved to dismiss on the merits 2026Accordingly, the Suarez court refused “to hold that noncompliance with Rule 651(c) may be excused on the basis of harmless error.” 224 Ill. 2d at 52 . ¶ 20 Likewise, Justice McLaren’s special concurrence in Nitz (see 2011 IL App (2d) 100031, ¶¶ 24-25 ), although expressed in terms of mootness, effectively imposes the same “no harm, no foul” rule, and so do the decisions in Kirkpatrick (see 2012 IL App (2d) 100898, ¶ 27 (“Once the State moved to dismiss on the merits and did not challenge the alleged procedural defects, and once the trial court conducted a hearing, during which neither party ra | 1 | 2 |
| People v. Turnergreen | 1 | 1 |
| In Re DCgreen | 1 | 1 |
| Towns v. Yellow Cab Co.green | 1 | 1 |
| Foutch v. O'BRYANTgreen | 1 | 1 |
| People v. Greergreen | 1 | 1 |
| People v. Warrgreen | 1 | 1 |
| People v. Childressgreen | 1 | 1 |
| In Re Marriage of Rickettsgreen | 1 | 1 |
| Terry v. Ohiogreen | 1 | 1 |
| People v. Smithgreen | 1 | 1 |
| Strickland v. Washingtongreen | 1 | 1 |
| People v. Smithgreen | 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. Krankel
green
2 sentences2025Defendant, pro se and through counsel, filed several motions to suppress the evidence obtained from the traffic stop, which the trial court denied. ¶2 In May 2022, a jury found defendant guilty of unlawful possession with the intent to deliver cocaine. ¶3 In July 2022, the trial court conducted an inquiry pursuant to People v. Krankel, 102 Ill. 2d 181 (1984), into defendant’s pro se claims of ineffective assistance of counsel and declined to appoint defendant new counsel. 2025Id. ¶5 On remand, the trial court appointed new counsel who filed a “Motion to Vacate Conviction and Appoint Effective Counsel.” In May 2024, the court conducted a hearing on that motion and denied it in a written order. ¶6 Defendant appeals, arguing (1) the trial court erred by (a) denying his motion to suppress evidence obtained from an improper traffic stop, (b) sustaining numerous State objections and limiting defense counsel’s ability to challenge the validity of the traffic stop, (c) denying defendant’s request to proceed pro se following trial, and (d) considering a factor inherent in t | 22 | 2009–2025 |
People v. Moore
green
2 sentences2023Id. at 79 . 6 ¶ 27 After reviewing the record, we find that the court conducted no inquiry into the defendant’s posttrial claims of ineffective assistance of counsel. 2021Id. at 74 . ¶ 52 On appeal, this court declared that “the trial court neither ‘denied’ the defendant’s pro se posttrial motion nor found the allegations therein to be ‘meritless’ ”; rather the trial court conducted no inquiry of any sort into defendant’s allegations. | 14 | 2005–2023 |
People v. Little
green
2 sentences2013Little, 207 Ill. 2008Little, 207 Ill. | 3 | 2008–2013 |
People v. Roddis
green
2 sentences2026Roddis, 2020 IL 124352, ¶ 36 . ¶ 55 Although we review de novo whether the trial court properly conducted a preliminary Krankel inquiry (Roddis, 2020 IL 124352, ¶ 33 ), where, as here, the trial court conducted the inquiry and ruled on the merits of the claim, we reverse only if the court’s ruling was manifestly erroneous. 2026Roddis, 2020 IL 124352, ¶ 36 . ¶ 55 Although we review de novo whether the trial court properly conducted a preliminary Krankel inquiry (Roddis, 2020 IL 124352, ¶ 33 ), where, as here, the trial court conducted the inquiry and ruled on the merits of the claim, we reverse only if the court’s ruling was manifestly erroneous. | 2 | 2020–2026 |
People v. Prince
green
2 sentences2024In addition, defendant contended that the court erred when it allowed the State’s evidence of uncharged offenses under section 115-7.4 of the Code because the State never identified why the evidence was relevant to the proceeding. -9- 2024 IL App (2d) 230027 ¶ 23 On October 2, 2020, the trial court conducted a hearing on defendant’s motions for new trial. 2024In addition, defendant contended that the court erred when it allowed the State’s evidence of uncharged offenses under section 115-7.4 of the Code because the State never identified why the evidence was relevant to the proceeding. -9- 2024 IL App (2d) 230027 ¶ 23 On October 2, 2020, the trial court conducted a hearing on defendant’s motions for new trial. | 2 | 2024–2024 |
Rein v. David A. Noyes & Co.
green
2 sentences2021Relying on Hudson v. City of Chicago, 228 Ill. 2d 462 (2008), and Rein v. David A. Noyes & Co., 172 Ill. 2d 325 (1996), the Hospital claimed that when “plaintiff voluntarily dismissed his suit, the final decisions with respect to the previously filed complaints, and not the third amended complaint, subjected plaintiff to the res judicata defense.” Ward opposed the motion. ¶ 39 The trial court conducted a hearing on the Hospital’s motion to reconsider. 2019Relying on Hudson v. City of Chicago, 228 Ill. 2d 462 (2008), and Rein v. David A. Noyes & Co., 172 Ill. 2d 325 (1996), the Hospital claimed that when “plaintiff voluntarily dismissed his suit, the final decisions with respect to the previously filed complaints, and not the third amended complaint, subjected plaintiff to the res judicata defense.” Ward opposed the motion. -9- ¶ 39 The trial court conducted a hearing on the Hospital’s motion to reconsider. | 2 | 2019–2021 |
Hudson v. City of Chicago
green
2 sentences2021Relying on Hudson v. City of Chicago, 228 Ill. 2d 462 (2008), and Rein v. David A. Noyes & Co., 172 Ill. 2d 325 (1996), the Hospital claimed that when “plaintiff voluntarily dismissed his suit, the final decisions with respect to the previously filed complaints, and not the third amended complaint, subjected plaintiff to the res judicata defense.” Ward opposed the motion. ¶ 39 The trial court conducted a hearing on the Hospital’s motion to reconsider. 2019Relying on Hudson v. City of Chicago, 228 Ill. 2d 462 (2008), and Rein v. David A. Noyes & Co., 172 Ill. 2d 325 (1996), the Hospital claimed that when “plaintiff voluntarily dismissed his suit, the final decisions with respect to the previously filed complaints, and not the third amended complaint, subjected plaintiff to the res judicata defense.” Ward opposed the motion. -9- ¶ 39 The trial court conducted a hearing on the Hospital’s motion to reconsider. | 2 | 2019–2021 |
Michael Moore v. Lisa Madigan
green
2 sentences2018Id. at 942 . 2018Id. at 942 . | 2 | 2018–2018 |
Neil v. Biggers
green
2 sentences2017In reaching this conclusion, the trial court conducted its analysis entirely within the framework of Neil v. Biggers, 409 U.S. 188 (1972), and People v. Slim, 127 Ill. 2d 302 (1989). 2017In reaching this conclusion, the trial court conducted its analysis entirely within the framework of Neil v. Biggers, 409 U.S. 188 (1972), and People v. Slim, 127 Ill. 2d 302 (1989). | 2 | 2017–2017 |
People v. Slim
green
2 sentences2017In reaching this conclusion, the trial court conducted its analysis entirely within the framework of Neil v. Biggers, 409 U.S. 188 (1972), and People v. Slim, 127 Ill. 2d 302 (1989). 2017In reaching this conclusion, the trial court conducted its analysis entirely within the framework of Neil v. Biggers, 409 U.S. 188 (1972), and People v. Slim, 127 Ill. 2d 302 (1989). | 2 | 2017–2017 |
The Estate of Mendelson v. Mendelson
green
2 sentences2016The counterpetition further alleged that he had paid the mortgage, real estate taxes, and upkeep and remodeling of the home out of his own funds from March 2004 through the date of the filing of the counterpetition. -4- 2016 IL App (2d) 150084 ¶ 14 From April 21 to May 9, 2014, the trial court conducted a hearing on the parties’ competing petitions. 2016The counterpetition further alleged that he had paid the mortgage, real estate taxes, and upkeep and remodeling of the home out of his own funds from March 2004 through the date of the filing of the counterpetition. -4- 2016 IL App (2d) 150084 ¶ 14 From April 21 to May 9, 2014, the trial court conducted a hearing on the parties’ competing petitions. | 2 | 2016–2016 |
People v. Welch
green
2 sentences2015Welch, 392 Ill. 2015Welch, 392 Ill. | 2 | 2015–2015 |
People v. Ames
green
2 sentences2015Nonetheless, the court relieved Elmore of his duties and purported to admonish defendant in accordance with Rule 401(a). ¶ 46 Almost three years ago, in People v. Ames, 2012 IL App (4th) 110513 , 978 N.E.2d 1119 , this court addressed another case in which the defendant successfully gamed the system by expressing his repeated displeasure with his court-appointed counsel. 2015Nonetheless, the court relieved Elmore of his duties and purported to admonish defendant in accordance with Rule 401(a). ¶ 46 Almost three years ago, in People v. Ames, 2012 IL App (4th) 110513 , 978 N.E.2d 1119 , this court addressed another case in which the defendant successfully gamed the system by expressing his repeated displeasure with his court-appointed counsel. | 2 | 2015–2015 |
People v. McKown
green
2 sentences2012Counsel argued that under People v. McKown, 236 Ill.2d 278 , 338 Ill.Dec. 415 , 924 N.E.2d 941 (2010) ( McKown I ), "the undue prejudice of [the HGN] evidence outweighs its probative value." Immediately before voir dire, the trial court conducted a hearing on defendant's motion in limine. 2012Counsel argued that under People v. McKown, 236 Ill.2d 278 , 338 Ill.Dec. 415 , 924 N.E.2d 941 (2010) ( McKown I ), "the undue prejudice of [the HGN] evidence outweighs its probative value." Immediately before voir dire, the trial court conducted a hearing on defendant's motion in limine. | 2 | 2012–2012 |
Marx Transport, Inc. v. Air Express International Corp.
green
2 sentences2009Marx Transport, 379 Ill. 2009Marx Transport, 379 Ill. | 2 | 2009–2009 |
Circle Management, LLC v. Olivier
green
2 sentences2008Circle Management, 378 Ill. 2008Circle Management, 378 Ill. | 2 | 2008–2008 |
People v. Lewis
green
2 sentences2006Indeed, this court conducted such an analysis in Lewis, 305 Ill. 2006Indeed, this court conducted such an analysis in Lewis, 305 Ill. | 2 | 2006–2006 |
People v. Stanley
green
2 sentences2006When the court indicated that it was prepared to vacate the robbery conviction, defendant cited People v. Stanley, 266 Ill. 2006When the court indicated that it was prepared to vacate the robbery conviction, defendant cited People v. Stanley, 266 Ill. | 2 | 2006–2006 |
People v. Camden
green
2 sentences2005Camden , 115 Ill. 2d at 373 . 2005Camden, 115 Ill. 2d at 373 . | 2 | 2005–2005 |
People v. Gilmore
green
2 sentences2005Indeed, the record does not show whether the trial court ever read defendant’s pro se posttrial motion.” We also echo the Second District: “We note that the trial court was not in a position to evaluate all of the ineffective assistance claims simply by relying on facts within its knowledge.” People v. Gilmore, 356 Ill. 2005Indeed, the record does not show whether the trial court ever read defendant's pro se posttrial motion." We also echo the Second District: "We note that the trial court was not in a position to evaluate all of the ineffective assistance claims simply by relying on facts within its knowledge." See People v. Gilmore , 356 Ill. | 2 | 2005–2005 |
People v. Rixie
green
2 sentences2003Rixie , 190 Ill. 2003Rixie, 190 Ill. | 2 | 2003–2003 |
People v. Hernandez
green
2 sentences2002The appellate court affirmed: "As petitioner points out, our supreme court did not issue an opinion addressing this issue until February 1996 *** From these facts, we cannot say that the trial court manifestly erred in finding that petitioner had shown that the delay in filing the petition was not due to his culpable negligence." Hernandez , 296 Ill. 2002The appellate court affirmed: “As petitioner points out, our supreme court did not issue an opinion addressing this issue until February 1996 ***. *** From these facts, we cannot say that the trial court manifestly erred in finding that petitioner had shown that the delay in filing the petition was not due to his culpable negligence.” Hernandez, 296 Ill. | 2 | 2002–2002 |
E & E HAULING, INC. v. County of Du Page
green
2 sentences2000The trial court relied on E&E Hauling, Inc. v. County of Du Page , 77 Ill. 2000The trial court relied on E & E Hauling, Inc. v. County of Du Page, 77 Ill.App.3d 1017 , 33 Ill.Dec. 536 , 396 N.E.2d 1260 (1979), and held that a public hearing must include a right of cross-examination. | 2 | 2000–2000 |
People v. Holmes
green
2 sentences1998Holmes , 141 Ill. 2d at 213 . 1998Holmes, 141 Ill. 2d at 213 . | 2 | 1998–1998 |
People v. Thiem
green
2 sentences1982App. 3d 956, 962 , 403 N.E.2d 647, 652 , the trial court conducted a hearing to set a maximum period of commitment for respondent. 1982App.3d 956, 962 , 403 N.E.2d 647, 652 , the trial court conducted a hearing to set a maximum period of commitment for respondent. | 2 | 1982–1982 |
Skaggs v. Junis
green
2 sentences1976App. 3d 614, 616 , 287 N.E.2d 731, 733 .) We further cited Skaggs v. Junis (1963), 28 Ill. 2d 199 , 190 N.E.2d 731 , for the proposition that the burden of preserving evidence rests with the party who appeals from the order where it is alleged that the evidence is insufficient to support the order. 1976App. 3d 614, 616 , 287 N.E.2d 731, 733 .) We further cited Skaggs v. Junis (1963), 28 Ill. 2d 199 , 190 N.E.2d 731 , for the proposition that the burden of preserving evidence rests with the party who appeals from the order where it is alleged that the evidence is insufficient to support the order. | 2 | 1972–1976 |
| People v. Vargas green | 1 | 2026–2026 |
| People v. Madison green | 1 | 2026–2026 |
| People v. Suarez green | 1 | 2026–2026 |
| People v. Nitz green | 1 | 2026–2026 |
| People v. Patel green | 1 | 2026–2026 |
| People v. Smith green | 1 | 2026–2026 |
| People v. Jackson green | 1 | 2026–2026 |
| People v. Price green | 1 | 2025–2025 |
| People v. One Black 2016 Jeep Wrangler Unlimited green | 1 | 2025–2025 |
| People v. Ferguson green | 1 | 2025–2025 |
| People v. Kyles green | 1 | 2025–2025 |
| People v. Robinson green | 1 | 2025–2025 |
| The People v. Montgomery green | 1 | 2024–2024 |
| People v. Zoph neutral | 1 | 2024–2024 |
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.