Mendoza-Martinez factors (Illinois) · Go Syfert
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Mendoza-Martinez factors in Illinois

19 Illinois opinions name it 2 courts 1992–2021 2 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 (8)

CaseFollowedCited
People v. Fredericksgreen
illappct · 2014 · cited in 7 Illinois opinions naming this issue, 2016–2019
2 sentences

2019Malchow , 193 Ill. 2d at 421 , 250 Ill.Dec. 670 , 739 N.E.2d 433 . ¶ 21 We previously applied the Mendoza-Martinez factors to the 2012 SORA in Fredericks , 2014 IL App (1st) 122122 , ¶ 58, 383 Ill.Dec. 293 , 14 N.E.3d 576 , and the 2014 SORA and Sex Offender Community Notification Law (Notification Law) ( 730 ILCS 152/101 et seq.

2019Malchow , 193 Ill. 2d at 421 , 250 Ill.Dec. 670 , 739 N.E.2d 433 . ¶ 21 We previously applied the Mendoza-Martinez factors to the 2012 SORA in Fredericks , 2014 IL App (1st) 122122 , ¶ 58, 383 Ill.Dec. 293 , 14 N.E.3d 576 , and the 2014 SORA and Sex Offender Community Notification Law (Notification Law) ( 730 ILCS 152/101 et seq.

37
Kennedy v. Mendoza-Martinezgreen
scotus · 1963 · cited in 7 Illinois opinions naming this issue, 1992–2021
2 sentences

2021The State, to its discredit, fails to address the manner in which defendant challenges the re-registration provision. -3- ¶ 14 On the merits, defendant, after recognizing a law must be both retroactive and disadvantageous to a defendant to violate the constitutional prohibitions against ex post facto laws, simply refers to the re-registration provision as retroactive and then presents a lengthy argument, using the Mendoza-Martinez factors (Kennedy v. Mendoza-Martinez, 372 U.S. 144 (1963)) and case law, why SORA, as a whole, has become punitive and therefore disadvantageous to a defendant.

2021The State, to its discredit, fails to address the manner in which defendant challenges the re-registration provision. -3- ¶ 14 On the merits, defendant, after recognizing a law must be both retroactive and disadvantageous to a defendant to violate the constitutional prohibitions against ex post facto laws, simply refers to the re-registration provision as retroactive and then presents a lengthy argument, using the Mendoza-Martinez factors (Kennedy v. Mendoza-Martinez, 372 U.S. 144 (1963)) and case law, why SORA, as a whole, has become punitive and therefore disadvantageous to a defendant.

17
People v. Malchowgreen
ill · 2000 · cited in 6 Illinois opinions naming this issue, 2017–2019
2 sentences

2019Malchow , 193 Ill. 2d at 421 , 250 Ill.Dec. 670 , 739 N.E.2d 433 . ¶ 21 We previously applied the Mendoza-Martinez factors to the 2012 SORA in Fredericks , 2014 IL App (1st) 122122 , ¶ 58, 383 Ill.Dec. 293 , 14 N.E.3d 576 , and the 2014 SORA and Sex Offender Community Notification Law (Notification Law) ( 730 ILCS 152/101 et seq.

2019Malchow , 193 Ill. 2d at 421 , 250 Ill.Dec. 670 , 739 N.E.2d 433 . ¶ 21 We previously applied the Mendoza-Martinez factors to the 2012 SORA in Fredericks , 2014 IL App (1st) 122122 , ¶ 58, 383 Ill.Dec. 293 , 14 N.E.3d 576 , and the 2014 SORA and Sex Offender Community Notification Law (Notification Law) ( 730 ILCS 152/101 et seq.

16
Smith v. Doegreen
scotus · 2003 · cited in 5 Illinois opinions naming this issue, 2016–2019
2 sentences

2016Smith, 538 U.S. at 90-92, 98-103 . ¶76 More recently, in Fredericks, 2014 IL App (1st) 122122, ¶¶ 58-61 , our court undertook a Mendoza-Martinez analysis of a recent amendment to SORA which provided that a sex offender convicted of any subsequent felony was required to register for life and concluded that the sex offender registration scheme has not transformed into a punishment since Malchow.

2016Smith, 538 U.S. at 90-92, 98-103 . ¶76 More recently, in Fredericks, 2014 IL App (1st) 122122, ¶¶ 58-61 , our court undertook a Mendoza-Martinez analysis of a recent amendment to SORA which provided that a sex offender convicted of any subsequent felony was required to register for life and concluded that the sex offender registration scheme has not transformed into a punishment since Malchow.

15
In re A.C.green
illappct · 2016 · cited in 3 Illinois opinions naming this issue, 2018–2019
2 sentences

2018See Malchow, 193 Ill. 2d at 421 . ¶ 16 We previously applied the Mendoza-Martinez factors to the 2013 SORA in Fredericks, 2014 IL App (1st) 122122, ¶ 58 , and A.C., 2016 IL App (1st) 153047, ¶¶ 77-78 , and determined that the changes to SORA since Malchow did not render the Act punitive.

2018See Malchow, 193 Ill. 2d at 421 . ¶ 16 We previously applied the Mendoza-Martinez factors to the 2013 SORA in Fredericks, 2014 IL App (1st) 122122, ¶ 58 , and A.C., 2016 IL App (1st) 153047, ¶¶ 77-78 , and determined that the changes to SORA since Malchow did not render the Act punitive.

13
People v. Dunngreen
illappct · 2020 · cited in 1 Illinois opinions naming this issue, 2021–2021
2 sentences

2021See People v. Dunn, 2020 IL App (1st) 150198, ¶ 20 (rejecting the defendant’s argument that “because his sex offender status prohibits him from certain residences or jobs, his liberty is effectively restrained”). ¶ 11 Moreover, our supreme court recently rejected a similar argument in People v. Johnson, 2021 IL 125738, ¶¶ 67, 69 , holding that the defendant’s obligation to register for life under the Child Murderer and Violent Offender Against Youth Registration Act (730 ILCS 154/1 et seq.

2021See People v. Dunn, 2020 IL App (1st) 150198, ¶ 20 (rejecting the defendant’s argument that “because his sex offender status prohibits him from certain residences or jobs, his liberty is effectively restrained”). ¶ 11 Moreover, our supreme court recently rejected a similar argument in People v. Johnson, 2021 IL 125738, ¶¶ 67, 69 , holding that the defendant’s obligation to register for life under the Child Murderer and Violent Offender Against Youth Registration Act (730 ILCS 154/1 et seq.

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

2021See People v. Dunn, 2020 IL App (1st) 150198, ¶ 20 (rejecting the defendant’s argument that “because his sex offender status prohibits him from certain residences or jobs, his liberty is effectively restrained”). ¶ 11 Moreover, our supreme court recently rejected a similar argument in People v. Johnson, 2021 IL 125738, ¶¶ 67, 69 , holding that the defendant’s obligation to register for life under the Child Murderer and Violent Offender Against Youth Registration Act (730 ILCS 154/1 et seq.

2021See People v. Dunn, 2020 IL App (1st) 150198, ¶ 20 (rejecting the defendant’s argument that “because his sex offender status prohibits him from certain residences or jobs, his liberty is effectively restrained”). ¶ 11 Moreover, our supreme court recently rejected a similar argument in People v. Johnson, 2021 IL 125738, ¶¶ 67, 69 , holding that the defendant’s obligation to register for life under the Child Murderer and Violent Offender Against Youth Registration Act (730 ILCS 154/1 et seq.

11
People v. Jonesgreen
illappct · 2018 · cited in 1 Illinois opinions naming this issue, 2020–2020
2 sentences

2020See People v. Jones, 2018 IL App (1st) 151307, ¶ 52 . - 13 - 1-18-1060 concluded the relevant version had no punitive intent or effect.

2020See People v. Jones, 2018 IL App (1st) 151307, ¶ 52 . - 13 - 1-18-1060 concluded the relevant version had no punitive intent or effect.

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 (2)

CaseCitedYears
People v. Tetter green
illappct · 2018
2 sentences

2019Tetter, 2018 IL App (3d) 150243, ¶ 59 . ¶ 61 The fourth and fifth Mendoza-Martinez factors—rational relationship to an alternative, nonpunitive purpose and whether the sanction appears excessive in relation to that nonpunitive purpose—were considered together in Tetter.

2018Tetter , 2018 IL App (3d) 150243 , ¶ 59. ¶ 61 The fourth and fifth Mendoza-Martinez factors-rational relationship to an alternative, nonpunitive purpose and whether the sanction appears excessive in relation to that nonpunitive purpose-were considered together in Tetter .

22018–2019
Weaver v. Graham green
scotus · 1981
2 sentences

2019We agree with the State. ¶ 21 With respect to retroactivity, "[t]he critical question is whether the law changes the legal consequences of acts completed before its effective date." Weaver , 450 U.S. at 31 , 101 S.Ct. 960 .

2019We agree with the State. ¶ 21 With respect to retroactivity, "[t]he critical question is whether the law changes the legal consequences of acts completed before its effective date." Weaver , 450 U.S. at 31 , 101 S.Ct. 960 .

22019–2019

Statutes the citing opinions construe

IL § 730 ILCS 150/3 (15) IL § 730 ILCS 150/1 (13) IL § 730 ILCS 152/101 (12) IL § 720 ILCS 5/11-9.3 (11) IL § 720 ILCS 5/11-9.4-1 (8) IL § 735 ILCS 5/21-101 (8) IL § 730 ILCS 5/5-5-3 (7) IL § 730 ILCS 150/6 (6) IL § 730 ILCS 150/3-5 (5) IL § 730 ILCS 150/7 (5) IL § 720 ILCS 5/11-1.60 (4) IL § 730 ILCS 152/121 (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

PA 65 (2003–2026) IL 19 (1992–2021) CA 17 (1999–2021) MI 16 (2014–2026) AZ 8 (1991–2020) IN 8 (2009–2019) WI 7 (2002–2021) ME 7 (2001–2015) CO 6 (2009–2026) KS 6 (1996–2017) IA 6 (1997–2021) MD 6 (1998–2020) NM 6 (2003–2015) NC 6 (2007–2010) WA 5 (1994–2023) OR 5 (1977–2024) NJ 4 (1995–2014) ND 4 (1999–1999) OH 4 (1998–2008) LA 3 (1987–2025) NY 3 (1988–2010) DC 2 (2004–2004) WV 2 (1992–2020) MN 2 (2014–2017) MA 2 (1996–2009) SC 2 (2013–2014) KY 2 (2010–2010) OK 2 (2013–2025) GA 2 (2018–2018) AL 2 (2004–2011) MT 2 (2003–2005) NV 2 (2013–2013) MS 2 (2005–2006)

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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