reasonable doubt standard in Illinois

2026Confrontation clause violations will be held harmless when “it appears beyond a reasonable doubt that the error at issue did not contribute to the verdict obtained.” Id.

2026Confrontation clause violations will be held harmless when “it appears beyond a reasonable doubt that the error at issue did not contribute to the verdict obtained.” Id.

2024Illinois law is clear that “neither the court nor counsel should attempt to define the reasonable doubt standard for the jury.” People v. Speight, 153 Ill. 2d 365, 374 (1992). ¶ 40 We do not find the State’s argument that reasonable doubt did not mean all doubt attempted to define the reasonable doubt standard; rather, counsel merely discussed the level of doubt the jury must have.

2023“Illinois law is clear that neither the court nor counsel should attempt to define the reasonable doubt standard for the jury (People v. Speight, 153 Ill. 2d 365, 374 (1992); People v. Malmenato, 14 Ill. 2d 52, 61 (1958)).

2020People v. Howery, 178 Ill. 2d 1, 38 (1997). ¶ 60 The reasonable doubt standard of review “gives full play to the responsibility of the trier of fact fairly to resolve conflicts in the testimony, to weigh the evidence, and to draw reasonable inferences from basic facts to ultimate facts.” Id. (quoting Jackson, 443 U.S. 307, 319 (1979). 15 No. 15-2862 Accordingly, a reviewing court will not retry a defendant on appeal or substitute its judgment for that of the trier of fact on issues involving the weight of the evidence or the credibility of the witnesses.

2019The reasonable doubt standard provides a direct corollary to the presumption of innocence and "plays a vital role in the American scheme of criminal procedure." (Internal quotation marks omitted.) Jackson v. Virginia , 443 U.S. 307 , 315, 99 S.Ct. 2781 , 61 L.Ed.2d 560 (1979).

2025Defendant contends that this improper testimony amounted to plain error under the first prong because the evidence was closely balanced. ¶ 73 “Whether the evidence is closely balanced is, of course, a separate question from whether the evidence is sufficient to sustain a conviction on review against a reasonable doubt challenge.” People v. Piatkowski, 225 Ill. 2d 551, 566 (2007).

2024Closely Balanced ¶ 68 “ ‘Whether the evidence is closely balanced is, of course, a separate question from whether the evidence is sufficient to sustain a conviction on review against a reasonable doubt challenge.’ ” Sebby, 2017 IL 119445, ¶ 60 (quoting Piatkowski, 225 Ill. 2d at 566 ).

2025Defendant argues that for this reason, the State cannot show that the constitutional error was harmless beyond a reasonable doubt. ¶ 141 Our supreme court in Patterson considered the question of whether a confrontation clause violation was harmless beyond a reasonable doubt, finding “the test to be applied is whether it appears beyond a reasonable doubt that the error at issue did not contribute to the verdict obtained.” - 54 - 2025 IL App (2d) 240194 Id. (citing Sullivan v. Louisiana, 508 U.S. 275, 279 (1993)).

2008Ed. 2d 182, 189 , 113 S. Ct. 2078, 2081-82 (1993) (finding harmless error analysis to be inappropriate in a case where the jury was misinstructed about the reasonable doubt standard, because “to hypothesize a guilty verdict that was never in fact rendered — no matter how inescapable the findings to support that verdict might be — would violate the jury-trial guarantee”); Rose v. Clark, 478 U.S. 570, 578 , 92 L.

2025The standard for review of trial court errors stated in Quintero derives (through People v. Herron, 215 Ill. 2d 167 (2005), and People v. Thurow, 203 Ill. 2d 352, 363 (2003)) from Chapman v. California, 386 U.S. 18, 24 (1967), where the United States Supreme Court said that, “before a federal constitutional error can be held harmless, the court must be able to declare a belief that it was harmless beyond a reasonable doubt.” ¶ 90 In In re E.H., 224 Ill. 2d at 180 , this court explained that the reasonable doubt standard applied to constitutional errors but that “evidentiary error is harmless w

2009Ed. 2d 705, 710 , 87 S. Ct. 824, 827 (1967) (“[i]n order for an error to be held harmless, a reviewing court must be satisfied beyond a reasonable doubt that the error did not contribute to the defendant’s conviction”).

2025See People v. Schott, 145 Ill. 2d 188, 202-03 (1991) (“The reasonable doubt test has taken the place of another specialized standard of review, the reasonable hypothesis of innocence test, a test which was formerly used in circumstantial evidence cases.”). ¶ 19 The standard of review for a challenge to the sufficiency of the evidence is “whether, viewing the evidence in the light most favorable to the State, ‘any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt.’ ” People v. Belknap, 2014 IL 117094, ¶ 67 (quoting People v. Collins, 106 Ill.

2024Id. § 33A-1(c)(2), (c)(3). ¶ 27 “When faced with a challenge to the sufficiency of the evidence, the reviewing court applies the reasonable doubt standard as set forth in People v. Collins (1985), 106 Ill. 2d 237, 261 .” People v. Campbell, 146 Ill. 2d 363, 374 (1992).

2021In People v. Pintos, 133 Ill. 2d 286 (1989), however, our supreme court affirmed that the reasonable doubt standard, not a reasonable hypothesis of innocence standard, applies to cases based on circumstantial evidence.

2021See People v. Pintos, 133 Ill. 2d 286, 291 (1989) (the reasonable doubt test is applicable in reviewing the sufficiency of the evidence in all criminal cases; “the reasonable hypothesis of innocence standard of review is no longer viable in Illinois”).

2026See People v. Thompson, 2013 IL App (1st) 113105, ¶¶ 90-91 (finding nothing improper with the State asserting that the reasonable doubt standard “isn’t beyond any doubt in the world, any crazy doubt” (emphasis omitted)); People v. Burney, 2011 IL App (4th) 100343, ¶¶ 66-68 (finding nothing improper with the State asserting that the reasonable doubt standard “does not mean beyond all doubt”); People v. Laugharn, 297 Ill.

2020See e.g., People 27 1-17-0250 v. Thompson, 2013 IL App (1st) 113105, ¶¶ 90-91 (finding nothing improper with the State asserting that the reasonable doubt standard “isn't beyond any doubt in the world, any crazy doubt”) (Emphasis omitted); People v. Burney, 2011 IL App (4th) 100343, ¶¶ 66-68 (finding nothing improper with the State asserting that the reasonable doubt standard “does not mean beyond all doubt”); People v. Laugharn, 297 Ill.

2004This right has formed the bedrock of constitutional criminal procedure for centuries: “Although virtually unanimous adherence to the reasonable-doubt standard in common-law jurisdictions may not conclusively establish it as a requirement of due process, such adherence does ‘reflect a profound judgment about the way in which law should be enforced and justice administered.’ ” In re Winship, 397 U.S. 358, 361-62 , 25 L.

2004This right has formed the bedrock of constitutional criminal procedure for centuries: “Although virtually unanimous adherence to the reasonable-doubt standard in common-law jurisdictions may not conclusively establish it as a requirement of due process, such adherence does ‘reflect a profound judgment about the way in which law should be enforced and justice administered.’ ” In re Winship, 397 U.S. 358, 361-62 , 25 L.

2022People v. Stechly, 225 Ill. 2d 246, 304 (2007). “[T]he test is whether it appears beyond a reasonable doubt that the error at issue did not contribute to the verdict obtained.” In re Rolandis G., 232 Ill. 2d 13, 43 (2008).

2017"The test is whether it appears beyond a reasonable doubt that the error at issue did not contribute to the verdict obtained." Stechly, 225 Ill. 2d at 304 (citing Patterson, 217 Ill. 2d at 428 ). 5 In Leach, defendant filed a motion in limine and the trial court held a pretrial hearing on the issue.

2022App. 3d at 961 . - 32 - Harmless-error review tests “whether it appears beyond a reasonable doubt that the error at issue did not contribute to the verdict obtained.” In re Rolandis G., 232 Ill. 2d 13, 43 , 902 N.E.2d 600, 617 (2008).

2022People v. Stechly, 225 Ill. 2d 246, 304 (2007). “[T]he test is whether it appears beyond a reasonable doubt that the error at issue did not contribute to the verdict obtained.” In re Rolandis G., 232 Ill. 2d 13, 43 (2008).

2020Although the United States Constitution does not prohibit courts from defining reasonable doubt (Victor v. Nebraska, 511 U.S. 1, 5 (1994)), Illinois law is clear that neither the court nor counsel should attempt to define the reasonable doubt standard for the jury (People v. Speight, 153 Ill. 2d 365, 374 (1992); People v. Malmenato, 14 Ill. 2d 52, 61 (1958)).

2020Although the United States Constitution does not prohibit courts from defining reasonable doubt (Victor v. Nebraska, 511 U.S. 1, 5 (1994)), Illinois law is clear that neither the court nor counsel should attempt to define the reasonable doubt standard for the jury (People v. Speight, 153 Ill. 2d 365, 374 (1992); People v. Malmenato, 14 Ill. 2d 52, 61 (1958)).

2026See People v. Thompson, 2013 IL App (1st) 113105, ¶¶ 90-91 (finding nothing improper with the State asserting that the reasonable doubt standard “isn’t beyond any doubt in the world, any crazy doubt” (emphasis omitted)); People v. Burney, 2011 IL App (4th) 100343, ¶¶ 66-68 (finding nothing improper with the State asserting that the reasonable doubt standard “does not mean beyond all doubt”); People v. Laugharn, 297 Ill.

2023Additionally, a “ ‘trial court can cure erroneous statements made during arguments by giving proper jury instructions on the law ***, telling the jury arguments are not evidence and should be disregarded if not supported by the evidence, or by sustaining an objection and instructing the jury to disregard the improper statement.’ ” People v. Price, 2021 IL App (4th) 190043, ¶ 154 (quoting People v. Kallal, 2019 IL App (4th) 180099, ¶ 35 ). ¶ 65 Courts disfavor attempts to explain the reasonable-doubt standard because the attempt, even if well-intentioned, “may distort the standard to the prejud

2023“Illinois law is clear that neither the court nor counsel should attempt to define the reasonable doubt standard for the jury (People v. Speight, 153 Ill. 2d 365, 374 (1992); People v. Malmenato, 14 Ill. 2d 52, 61 (1958)).

2020Although the United States Constitution does not prohibit courts from defining reasonable doubt (Victor v. Nebraska, 511 U.S. 1, 5 (1994)), Illinois law is clear that neither the court nor counsel should attempt to define the reasonable doubt standard for the jury (People v. Speight, 153 Ill. 2d 365, 374 (1992); People v. Malmenato, 14 Ill. 2d 52, 61 (1958)).

2023“Attempts to explain the reasonable doubt standard have been disfavored by the courts because ‘no matter how well-intentioned, the attempt may distort the standard to the prejudice of the defendant.’ ” People v. Burney, 2011 IL App. (4th) 100343, ¶ 67 (quoting People v. Keene, 169 Ill.2d 1, 25 (1995)).

2021Courts disfavor attempts by counsel to explain the reasonable doubt standard because “no matter how well-intentioned, the attempt may distort the standard to the prejudice of the defendant.” People v. Keene, 169 Ill. 2d 1 , 24- 25 (1995).

2025Pierre, 122 Ill. 2d 95, 113-14 (1988); see also People v. Fort, 2014 IL App (1st) 120037, ¶ 19 ; and People v. Patterson, 217 Ill. 2d 407, 428 (2005).

2014Pierre, 122 Ill. 2d 95, 113-14 (1988) (error may only be held harmless where the reviewing court is satisfied beyond a reasonable doubt that the error did not contribute to the defendant’s conviction). ¶ 54 III.

2024“During this phase, the trial court applies the reasonable doubt standard of proof and the rules of evidence that would be followed in a criminal case to determine whether the minor should be found delinquent.” Id.

2018“During this phase, the trial court applies the reasonable doubt standard of proof and the rules of evidence that would be followed in a criminal case to determine whether the minor should be found delinquent.” In re Samantha V., 234 Ill. 2d at 365.

2013Although the United States Constitution does not prohibit courts from defining reasonable doubt (Victor v. Nebraska, 511 U.S. 1, 5 (1994)), the Illinois Supreme Court has stated that “[t]he law in Illinois is clear that neither the court nor counsel should attempt to define the reasonable doubt standard for the jury” (People v. Speight, 153 Ill. 2d 365, 374 (1992) (citing People v. Cagle, 41 Ill. 2d 528, 536 (1969), and People v. Malmenato, 14 Ill. 2d 52, 61 (1958))). ¶ 42 “Reasonable doubt is a term which needs no elaboration and we have so frequently discussed the futility of attempting to d

2012“The law in Illinois is clear that neither the court nor counsel should attempt to define the reasonable doubt standard for the jury.” People v. Speight, 153 Ill. 2d 365, 374 (1992) (citing People v. Cagle, 41 Ill. 2d 528, 536 (1969), and People v. Malmenato, 14 Ill. 2d 52, 61 (1958)).

2025See People v. Schott, 145 Ill. 2d 188, 202-03 (1991) (“The reasonable doubt test has taken the place of another specialized standard of review, the reasonable hypothesis of innocence test, a test which was formerly used in circumstantial evidence cases.”). ¶ 19 The standard of review for a challenge to the sufficiency of the evidence is “whether, viewing the evidence in the light most favorable to the State, ‘any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt.’ ” People v. Belknap, 2014 IL 117094, ¶ 67 (quoting People v. Collins, 106 Ill.

2019See People v. Schott, 145 Ill. 2d 188, 202-03 (1991) (“The reasonable doubt test has taken the place of another specialized standard of review, the -37- 2019 IL App (2d) 180124 reasonable hypothesis of innocence test, a test which was formerly used in circumstantial evidence cases.”).

2012Dec. 931 , 888 N.E.2d 148, 154 (2008); see also In re Jonathon C.B., 2011 IL 107750, ¶ 47 , 354 Ill.Dec. 484 , 958 N.E.2d 227, 238 (noting the reasonable-doubt standard applies in delinquency proceedings).

2012"The reasonable doubt standard asks whether, viewing the evidence in the light most favorable to the prosecution, any rational trier of fact could have found the essential elements of the crime beyond a reasonable doubt." Jonathon C.B., 2011 IL 107750, ¶ 47 , 354 Ill.Dec. 484 , 958 N.E.2d at 238 .

2024Id. § 33A-1(c)(2), (c)(3). ¶ 27 “When faced with a challenge to the sufficiency of the evidence, the reviewing court applies the reasonable doubt standard as set forth in People v. Collins (1985), 106 Ill. 2d 237, 261 .” People v. Campbell, 146 Ill. 2d 363, 374 (1992).

1995Ed. 2d 560, 573 , 99 S. Ct. 2781, 2789 ; People v. Campbell (1992), 146 Ill. 2d 363, 374 ; Sanchez, 115 Ill. 2d at 261 ; Collins, 106 Ill. 2d at 261 .) This reasonable doubt standard is applicable in reviewing the sufficiency of evidence in all criminal cases, regardless of whether the evidence is direct or circumstantial.

2024Closely Balanced ¶ 68 “ ‘Whether the evidence is closely balanced is, of course, a separate question from whether the evidence is sufficient to sustain a conviction on review against a reasonable doubt challenge.’ ” Sebby, 2017 IL 119445, ¶ 60 (quoting Piatkowski, 225 Ill. 2d at 566 ).

2022See Sebby, 2017 IL 119445, ¶ 60 (in discussing first-prong plain error analysis, “[t]he issue before us *** does not involve the sufficiency of close evidence but rather the closeness of sufficient evidence.”); Piatkowski, 225 Ill. 2d at 566 (“Whether the evidence is closely balanced is *** a separate question from whether the evidence is sufficient to sustain a conviction on review against a reasonable doubt challenge.”). - 50 - No. 1-18-1733 Further, the jury’s note to the court during deliberations indicated that it wrestled with the causation issue.

1977(People v. Smith (1967), 38 Ill. 2d 13 , 230 N.E.2d 188 .) The reviewing court must be satisfied beyond a reasonable doubt that the error did not contribute to the defendant’s conviction.

1977(People v. Smith (1967), 38 Ill. 2d 13 , 230 N.E.2d 188 .) The reviewing court must be satisfied beyond a reasonable doubt that the error did not contribute to the defendant’s conviction.

2015Veronica C., 239 Ill. 2d at 144 ; Sammantha V., 234 Ill. 2d at 365 ("the adjudication phase" is "where the court determines whether *** to make the minor a ward of the court"). ¶ 26 During the first or "findings" stage, "the trial court applies the reasonable doubt standard of proof and the rules of evidence that would be followed in a 8 No. 1-14-3181 criminal case, to determine whether the minor is guilty as charged and should thus be adjudged delinquent." Veronica C., 239 Ill. 2d at 144 ; Sammantha V., 234 Ill. 2d at 365; Stralka, 226 Ill. 2d at 452 .

2015Veronica C., 239 Ill. 2d at 144 ; Sammantha V., 234 Ill. 2d at 365 ("the adjudication phase" is "where the court determines whether *** to make the minor a ward of the court"). ¶ 26 During the first or "findings" stage, "the trial court applies the reasonable doubt standard of proof and the rules of evidence that would be followed in a 8 No. 1-14-3181 criminal case, to determine whether the minor is guilty as charged and should thus be adjudged delinquent." Veronica C., 239 Ill. 2d at 144 ; Sammantha V., 234 Ill. 2d at 365; Stralka, 226 Ill. 2d at 452 .