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125 Illinois opinions name it 2 courts 1991–2026 23 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. Walkergreen2 sentences2025However, the supreme court has stated: “The plain-error doctrine is a limited and narrow exception to the general rule of procedural default [citation] and allows a reviewing court to consider unpreserved error when one of two conditions is met: ‘(1) a clear or obvious error occurred and the evidence is so closely balanced that the error alone threatened to tip the scales of justice against the defendant, regardless of the seriousness of the error, or (2) a clear or obvious error occurred and that error is so serious that it affected the fairness of the defendant’s trial and challenged the int 2016Finally, he maintains fines imposed by the circuit clerk are void and he is entitled to $1380 in presentence credit. ¶ 43 A. Plain Error ¶ 44 “The plain-error doctrine is a limited and narrow exception to the general rule of procedural default ***.” People v. Walker, 232 Ill. 2d 113, 124 , 902 N.E.2d 691, 697 (2009). | 18 | 20 |
People v. Kuntugreen2 sentences2003Plain error is a limited and narrow exception to the general waiver rule, and is invoked only where the evidence is closely balanced, or where the alleged error is so substantial that it deprived the defendant of a fair trial. *878 People v. Kuntu, 196 Ill.2d 105, 128 , 256 Ill.Dec. 500 , 752 N.E.2d 380 (2001). 2003Plain error is a limited and narrow exception to the general waiver rule, and is invoked only where the evidence is closely balanced, or where the alleged error is so substantial that it deprived the defendant of a fair trial. *878 People v. Kuntu, 196 Ill.2d 105, 128 , 256 Ill.Dec. 500 , 752 N.E.2d 380 (2001). | 15 | 15 |
People v. Piatkowskigreen2 sentences2025However, the supreme court has stated: “The plain-error doctrine is a limited and narrow exception to the general rule of procedural default [citation] and allows a reviewing court to consider unpreserved error when one of two conditions is met: ‘(1) a clear or obvious error occurred and the evidence is so closely balanced that the error alone threatened to tip the scales of justice against the defendant, regardless of the seriousness of the error, or (2) a clear or obvious error occurred and that error is so serious that it affected the fairness of the defendant’s trial and challenged the int 2015Defendant argues that despite failing to object to voir dire at trial, we should review this issue under the first prong of the plain-error doctrine, as the evidence is closely balanced. 10 ¶ 35 The plain-error doctrine is a limited and narrow exception to the general rule of procedural default (People v. Naylor, 229 Ill. 2d 584, 593 (2008)) and allows a reviewing court to consider unpreserved error when one of two conditions is met: “ ‘(1) a clear or obvious error occurred and the evidence is so closely balanced that the error alone threatened to tip the scales of justice against the defendan | 14 | 15 |
People v. Herrongreen2 sentences2008Plain error is a limited and narrow exception to the general waiver rule, invoked only where: (1) the evidence is closely balanced; or (2) the alleged error is so substantial that it deprives the defendant of a fair trial. 134 Ill. 2d R. 615(a); People v. Herron, 215 Ill. 2d 167, 186-87 (2005). 2008Plain error is a limited and narrow exception to the general waiver rule, invoked only where: (1) the evidence is closely balanced; or (2) the alleged error is so substantial that it deprives the defendant of a fair trial. 134 Ill. 2d R. 615(a); People v. Herron, 215 Ill. 2d 167, 186-87 (2005). | 12 | 13 |
People v. Hilliergreen2 sentences2023“In the sentencing context, a defendant must *** show either that (1) the evidence at the sentencing hearing was closely balanced, or (2) the error was so egregious as to deny the defendant a fair sentencing hearing.” People v. Hillier, 237 Ill. 2d 539, 545 (2010). ¶ 17 “A claim of ineffective assistance of counsel requires a defendant to establish [(1)] that his attorney’s performance fell below an objective standard of reasonableness and [(2)] that there is a reasonable probability that, but for counsel’s unprofessional errors, the result of the proceeding would have been different.” People 2023Hillier, 237 Ill. 2d at 545 . | 8 | 13 |
People v. Bakergreen2 sentences2022Rather, it is a limited and narrow exception ‘designed to redress serious injustices.’ ” People v. Scott, 2015 IL App (4th) 130222, ¶ 41 (quoting People v. Baker, 341 Ill. 2018"Rather, it is a limited and narrow exception 'designed to redress serious injustices.' " Id. (quoting People v. Baker , 341 Ill. | 5 | 6 |
People v. Hamptongreen2 sentences2016People v. Hampton, 149 Ill. 2d 71, 100 (1992). 2003People v. Hampton, 149 Ill. 2d 71, 100 (1992). | 5 | 5 |
People v. Herrettgreen2 sentences2003People v. Coffee , No. 86975, October 18, 2001, 2001 WL 1243638 ; citing People v. Herrett , 137 Ill. 2d 195, 209-10 (1990). 2003People v. Caffey, 205 Ill. 2d 52, 103 (2001), citing People v. Herrett, 137 Ill. 2d 195, 209-10 (1990); People v. Carlson, 79 Ill. 2d 564, 576-77 (1980). | 4 | 4 |
In Re Detention of Traynoffgreen2 sentences2006However, "[p]lain error is a limited and narrow exception to the general waiver rule." In re Detention of Traynoff, 338 Ill.App.3d 949, 963 , 273 Ill.Dec. 691 , 789 N.E.2d 865 (2003). 2006However, “[p]lain error is a limited and narrow exception to the general waiver rule.” In re Detention ofTraynoff, 338 Ill. | 3 | 7 |
People v. Naylorgreen2 sentences2015Defendant argues that despite failing to object to voir dire at trial, we should review this issue under the first prong of the plain-error doctrine, as the evidence is closely balanced. 10 ¶ 35 The plain-error doctrine is a limited and narrow exception to the general rule of procedural default (People v. Naylor, 229 Ill. 2d 584, 593 (2008)) and allows a reviewing court to consider unpreserved error when one of two conditions is met: “ ‘(1) a clear or obvious error occurred and the evidence is so closely balanced that the error alone threatened to tip the scales of justice against the defendan 2015Defendant argues that despite failing to object to voir dire at trial, we should review this issue under the first prong of the plain-error doctrine, as the evidence is closely balanced. 10 ¶ 35 The plain-error doctrine is a limited and narrow exception to the general rule of procedural default (People v. Naylor, 229 Ill. 2d 584, 593 (2008)) and allows a reviewing court to consider unpreserved error when one of two conditions is met: “ ‘(1) a clear or obvious error occurred and the evidence is so closely balanced that the error alone threatened to tip the scales of justice against the defendan | 3 | 6 |
People v. Lewisgreen2 sentences2019People v. Lewis , 234 Ill. 2d 32 , 42, 332 Ill.Dec. 334 , 912 N.E.2d 1220 (2009). 2019People v. Lewis , 234 Ill. 2d 32 , 42, 332 Ill.Dec. 334 , 912 N.E.2d 1220 (2009). | 3 | 4 |
People v. Caffeygreen2 sentences2003Plain errors are those that affect something that is “ ‘fundamental to the integrity of the judicial process.’ ” Keene, 169 Ill. 2d at 17 , 660 N.E.2d at 910 , quoting People v. Green, 74 Ill. 2d 444, 456 , 386 N.E.2d 272, 278 (1979) (Ryan, J., specially concurring); see also People v. Caffey, 205 Ill. 2d 52, 103 , 792 N.E.2d 1163, 1196 (2001) (reiterating that plain error is “a limited and narrow exception” to the waiver rule). 2003Plain errors are those that affect something that is “ ‘fundamental to the integrity of the judicial process.’ ” Keene, 169 Ill. 2d at 17 , 660 N.E.2d at 910 , quoting People v. Green, 74 Ill. 2d 444, 456 , 386 N.E.2d 272, 278 (1979) (Ryan, J., specially concurring); see also People v. Caffey, 205 Ill. 2d 52, 103 , 792 N.E.2d 1163, 1196 (2001) (reiterating that plain error is “a limited and narrow exception” to the waiver rule). | 3 | 3 |
People v. Carlsongreen2 sentences2003People v. Caffey, 205 Ill. 2d 52, 103 (2001), citing People v. Herrett, 137 Ill. 2d 195, 209-10 (1990); People v. Carlson, 79 Ill. 2d 564, 576-77 (1980). 2001People v. Herrett, 137 Ill. 2d 195, 209-10 (1990); People v. Carlson, 79 Ill. 2d 564, 576-77 (1980). | 3 | 3 |
Fellhauer v. City of Genevagreen2 sentences1992While the common law doctrine that an employer may discharge an at-will employee for any reason or for no reason is still the general rule in Illinois, the tort of retaliatory discharge has been held to be a limited and narrow exception to this general rule. ( Fellhauer v. City of Geneva (1991), 142 Ill.2d 495 , 154 Ill.Dec. 649 , 568 N.E.2d 870 ; Thomas v. Zamberletti (1985), 134 Ill. 1992While the common law doctrine that an employer may discharge an at-will employee for any reason or for no reason is still the general rule in Illinois, the tort of retaliatory discharge has been held to be a limited and narrow exception to this general rule. ( Fellhauer v. City of Geneva (1991), 142 Ill.2d 495 , 154 Ill.Dec. 649 , 568 N.E.2d 870 ; Thomas v. Zamberletti (1985), 134 Ill. | 2 | 6 |
Palmateer v. International Harvester Co.green2 sentences2004"The tort of retaliatory discharge is a limited and narrow exception to the general rule that an at-will employee is terminable at any time for any or no cause." Geary v. Telular Corp., 341 Ill.App.3d 694, 700 , 275 Ill.Dec. 648 , 793 N.E.2d 128, 133 (2003); Palmateer v. International Harvester Co., 85 Ill.2d 124, 128 , 52 Ill.Dec. 13 , 421 N.E.2d 876, 878 (1981). 2004"The tort of retaliatory discharge is a limited and narrow exception to the general rule that an at-will employee is terminable at any time for any or no cause." Geary v. Telular Corp., 341 Ill.App.3d 694, 700 , 275 Ill.Dec. 648 , 793 N.E.2d 128, 133 (2003); Palmateer v. International Harvester Co., 85 Ill.2d 124, 128 , 52 Ill.Dec. 13 , 421 N.E.2d 876, 878 (1981). | 2 | 5 |
People v. Harveygreen2 sentences2017People v. Harvey, 211 Ill. 2d 368, 385 , 813 N.E.2d 181, 192 (2004). 2017People v. Harvey, 211 Ill. 2d 368, 385 , 813 N.E.2d 181, 192 (2004). | 2 | 2 |
People v. Cejagreen2 sentences2006People v. Ceja, 204 Ill. 2d 332, 353 (2003). 2006People v, Ceja, 204 Ill. 2d 332, 353 (2003). | 2 | 2 |
Geary v. Telular Corp.green2 sentences2004"The tort of retaliatory discharge is a limited and narrow exception to the general rule that an at-will employee is terminable at any time for any or no cause." Geary v. Telular Corp., 341 Ill.App.3d 694, 700 , 275 Ill.Dec. 648 , 793 N.E.2d 128, 133 (2003); Palmateer v. International Harvester Co., 85 Ill.2d 124, 128 , 52 Ill.Dec. 13 , 421 N.E.2d 876, 878 (1981). 2004“The tort of retaliatory discharge is a limited and narrow exception to the general rule that an at-will employee is terminable at any time for any or no cause.” Geary v. Telular Corp., 341 Ill. | 2 | 2 |
People v. Greengreen2 sentences2003Plain errors are those that affect something that is “ ‘fundamental to the integrity of the judicial process.’ ” Keene, 169 Ill. 2d at 17 , 660 N.E.2d at 910 , quoting People v. Green, 74 Ill. 2d 444, 456 , 386 N.E.2d 272, 278 (1979) (Ryan, J., specially concurring); see also People v. Caffey, 205 Ill. 2d 52, 103 , 792 N.E.2d 1163, 1196 (2001) (reiterating that plain error is “a limited and narrow exception” to the waiver rule). 2003Plain errors are those that affect something that is “ ‘fundamental to the integrity of the judicial process.’ ” Keene, 169 Ill. 2d at 17 , 660 N.E.2d at 910 , quoting People v. Green, 74 Ill. 2d 444, 456 , 386 N.E.2d 272, 278 (1979) (Ryan, J., specially concurring); see also People v. Caffey, 205 Ill. 2d 52, 103 , 792 N.E.2d 1163, 1196 (2001) (reiterating that plain error is “a limited and narrow exception” to the waiver rule). | 2 | 2 |
| People v. Bullgreen | 2 | 2 |
People v. Scottgreen2 sentences2022Rather, it is a limited and narrow exception ‘designed to redress serious injustices.’ ” People v. Scott, 2015 IL App (4th) 130222, ¶ 41 (quoting People v. Baker, 341 Ill. 2018"Rather, it is a limited and narrow exception 'designed to redress serious injustices.' " Id. (quoting People v. Baker , 341 Ill. | 1 | 3 |
Hinthorn v. Roland's of Bloomington, Inc.green2 sentences2007Hinthorn v. Roland’s of Bloomington, Inc., 119 Ill. 2d 526, 529 (1988). 1992(Hinthorn v. Roland’s of Bloomington, Inc. (1988), 119 Ill. 2d 526 , 519 N.E.2d 909 .) With these principles in mind, we now consider whether the plaintiff’s complaint was sufficient to withstand a motion to dismiss. | 1 | 2 |
| Balla v. Gambro, Inc.green | 1 | 2 |
| Beacham v. Walkergreen | 1 | 1 |
| People v. McCartygreen | 1 | 1 |
| Buckner v. Atlantic Plant Maintenance, Inc.green | 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. Walsh
green
2 sentences2025“Plain error is a limited and narrow exception to the general forfeiture rule.” Walsh, 2016 IL App (2d) 140357, ¶ 17 . 2023Nevertheless, he contends that we may consider the issue (1) under the plain-error rule or (2) because defense counsel was ineffective for failing to raise the issue in the trial court. ¶ 16 “ ‘Plain error is a limited and narrow exception to the general forfeiture rule.’ ” Id. ¶ 14 (quoting People v. Walsh, 2016 IL App (2d) 140357, ¶ 17 ). “ ‘To obtain relief under the plain- error rule, a defendant must show that a clear or obvious error occurred.’ ” Id. (quoting Walsh, 2016 IL App (2d) 140357, ¶ 17 ). “ ‘If a clear or obvious error is identified, a defendant may obtain -5- 2023 IL App (2d) | 6 | 2021–2025 |
Wieseman v. Kienstra, Inc.
green
2 sentences1998A retaliatory discharge tort is a limited and narrow exception ( Wieseman v. Kienstra, Inc. , 237 Ill. 1998A retaliatory discharge tort is a limited and narrow exception (Wieseman v. Kienstra, Inc., 237 Ill. | 4 | 1996–1998 |
In re Matter of Chance H.
green
2 sentences2024Nonetheless, respondent urges we should find there was plain error. - 16 - 1-23-1727 ¶ 57 “We may review an unpreserved error under the plain error doctrine found in Illinois Supreme Court Rule 615(a) (Jan. 1, 1967), which provides a limited and narrow exception to the general rule of procedural default.” In re Chance H., 2019 IL App (1st) 180053, ¶ 47 . 2024Nonetheless, respondent urges we should find there was plain error. ¶ 58 “We may review an unpreserved error under the plain error doctrine found in Illinois Supreme Court Rule 615(a) (Jan. 1, 1967), which provides a limited and narrow exception to the general rule of procedural default.” Matter of Chance H., 2019 IL App (1st) 180053, ¶ 47 . | 2 | 2024–2024 |
People v. Sebby
green
2 sentences2021People v. Sebby, 2017 IL 119445, ¶ 48 ; People v. Walker, 232 Ill. 2d 113, 124 (2009); People v. Piatkowski, 225 Ill. 2d 551, 565 (2007); People v. Herron, 215 Ill. 2d 167, 177-87 (2005); Ill. 2020People v. Sebby, 2017 IL 119445, ¶ 48 ; People v. Walker, 232 Ill. 2d 113, 124 (2009); People v. Piatkowski, 225 Ill. 2d 551, 565 (2007); People v. Herron, 215 Ill. 2d 167, 177-87 (2005); Ill. | 2 | 2020–2021 |
People v. Taylor
green
2 sentences2016“Under the plain-error doctrine, this court will review forfeited challenges when: (1) a clear or - 19 - obvious error occurred and the evidence is so closely balanced that the error alone threatened to tip the scales of justice against the defendant; or (2) a clear or obvious error occurred, and the error is so serious that it affected the fairness of the defendant’s trial and the integrity of the judicial process, regardless of the closeness of the evidence.” People v. Taylor, 2011 IL 110067, ¶ 30 , 956 N.E.2d 431 . 2015"Under the plain-error doctrine, this court will review forfeited challenges when: (1) a clear or obvious error occurred and the evidence is so closely balanced that the error alone threatened to tip the scales of justice against the defendant; or (2) a clear or obvious error occurred, and the error is so serious that it affected the fairness of the defendant's trial and the integrity of the judicial process, regardless of the closeness of the evidence." People v. Taylor, 2011 IL 110067, ¶ 30 , 956 N.E.2d 431 . | 2 | 2015–2016 |
People v. Taylor
green
2 sentences2016“Under the plain-error doctrine, this court will review forfeited challenges when: (1) a clear or - 19 - obvious error occurred and the evidence is so closely balanced that the error alone threatened to tip the scales of justice against the defendant; or (2) a clear or obvious error occurred, and the error is so serious that it affected the fairness of the defendant’s trial and the integrity of the judicial process, regardless of the closeness of the evidence.” People v. Taylor, 2011 IL 110067, ¶ 30 , 956 N.E.2d 431 . 2015"Under the plain-error doctrine, this court will review forfeited challenges when: (1) a clear or obvious error occurred and the evidence is so closely balanced that the error alone threatened to tip the scales of justice against the defendant; or (2) a clear or obvious error occurred, and the error is so serious that it affected the fairness of the defendant's trial and the integrity of the judicial process, regardless of the closeness of the evidence." People v. Taylor, 2011 IL 110067, ¶ 30 , 956 N.E.2d 431 . | 2 | 2015–2016 |
Krum v. Chicago National League Ball Club, Inc.
green
2 sentences2007Krum v. Chicago National League Ball Club, Inc., 365 Ill. 2007Krum v. Chicago National League Ball Club, Inc., 365 Ill. | 2 | 2007–2007 |
Jacobson v. Knepper & Moga, P.C.
green
2 sentences2004Jacobson , 185 Ill. 2d at 376 . 2004Jacobson, 185 Ill. 2d at 376 . | 2 | 2004–2004 |
Paris v. Cherry Payment Systems, Inc.
green
2 sentences2003Paris v. Cherry Payment Systems, Inc. , 265 Ill. 2003Paris v. Cherry Payment Systems, Inc., 265 Ill. | 2 | 2003–2003 |
| People v. Keene green | 2 | 2003–2003 |
| Ludwig v. C & a WALLCOVERINGS, INC. green | 2 | 1992–1994 |
| People v. Hartfield green | 1 | 2025–2025 |
| People v. Williams green | 1 | 2025–2025 |
| Turner v. Memorial Medical Center green | 1 | 2025–2025 |
| People v. Johnson green | 1 | 2023–2023 |
| People v. Veach green | 1 | 2023–2023 |
| People v. Miller green | 1 | 2023–2023 |
| Sweeney v. The City of Decatur green | 1 | 2022–2022 |
| People v. Coats green | 1 | 2021–2021 |
| People v. Rebollar-Vergara green | 1 | 2021–2021 |
| People v. Lewis green | 1 | 2019–2019 |
| People v. Belmont green | 1 | 2018–2018 |
| People v. Belknap green | 1 | 2015–2015 |
| Dowell v. Bitner green | 1 | 2006–2006 |
| Hindo v. University of Health Sciences/Chicago Medical School green | 1 | 1994–1994 |
| People v. Owens green | 1 | 1993–1993 |
| People v. Pastorino green | 1 | 1993–1993 |
| Hartlein v. Illinois Power Co. green | 1 | 1992–1992 |
| Thomas v. Zamberletti green | 1 | 1992–1992 |
| Mae McEwen v. Delta Air Lines, Inc. green | 1 | 1992–1992 |
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.