limited and narrow exception (Illinois) · Go Syfert
← Illinois issues

limited and narrow exception in Illinois

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.

Followed or applied (26)

CaseFollowedCited
People v. Walkergreen
ill · 2009 · cited in 20 Illinois opinions naming this issue, 2012–2025
2 sentences

2025However, 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).

1820
People v. Kuntugreen
ill · 2001 · cited in 15 Illinois opinions naming this issue, 2002–2005
2 sentences

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).

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).

1515
People v. Piatkowskigreen
ill · 2007 · cited in 15 Illinois opinions naming this issue, 2009–2025
2 sentences

2025However, 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

1415
People v. Herrongreen
ill · 2005 · cited in 13 Illinois opinions naming this issue, 2008–2026
2 sentences

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).

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).

1213
People v. Hilliergreen
ill · 2010 · cited in 13 Illinois opinions naming this issue, 2014–2023
2 sentences

2023“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 .

813
People v. Bakergreen
illappct · 2003 · cited in 6 Illinois opinions naming this issue, 2015–2022
2 sentences

2022Rather, 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.

56
People v. Hamptongreen
ill · 1992 · cited in 5 Illinois opinions naming this issue, 2001–2016
2 sentences

2016People v. Hampton, 149 Ill. 2d 71, 100 (1992).

2003People v. Hampton, 149 Ill. 2d 71, 100 (1992).

55
People v. Herrettgreen
ill · 1990 · cited in 4 Illinois opinions naming this issue, 2001–2003
2 sentences

2003People 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).

44
In Re Detention of Traynoffgreen
illappct · 2003 · cited in 7 Illinois opinions naming this issue, 2004–2006
2 sentences

2006However, "[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.

37
People v. Naylorgreen
ill · 2008 · cited in 6 Illinois opinions naming this issue, 2009–2015
2 sentences

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

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

36
People v. Lewisgreen
ill · 2009 · cited in 4 Illinois opinions naming this issue, 2016–2019
2 sentences

2019People 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).

34
People v. Caffeygreen
ill · 2001 · cited in 3 Illinois opinions naming this issue, 2003–2003
2 sentences

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).

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).

33
People v. Carlsongreen
ill · 1980 · cited in 3 Illinois opinions naming this issue, 2001–2003
2 sentences

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).

2001People v. Herrett, 137 Ill. 2d 195, 209-10 (1990); People v. Carlson, 79 Ill. 2d 564, 576-77 (1980).

33
Fellhauer v. City of Genevagreen
ill · 1991 · cited in 6 Illinois opinions naming this issue, 1991–2019
2 sentences

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.

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.

26
Palmateer v. International Harvester Co.green
ill · 1981 · cited in 5 Illinois opinions naming this issue, 1991–2004
2 sentences

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).

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).

25
People v. Harveygreen
ill · 2004 · cited in 2 Illinois opinions naming this issue, 2017–2017
2 sentences

2017People 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).

22
People v. Cejagreen
ill · 2003 · cited in 2 Illinois opinions naming this issue, 2006–2006
2 sentences

2006People v. Ceja, 204 Ill. 2d 332, 353 (2003).

2006People v, Ceja, 204 Ill. 2d 332, 353 (2003).

22
Geary v. Telular Corp.green
illappct · 2003 · cited in 2 Illinois opinions naming this issue, 2004–2004
2 sentences

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).

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.

22
People v. Greengreen
ill · 1979 · cited in 2 Illinois opinions naming this issue, 2003–2003
2 sentences

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).

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).

22
People v. Bullgreen
ill · 1998 · cited in 2 Illinois opinions naming this issue, 2002–2002
22
People v. Scottgreen
illappct · 2015 · cited in 3 Illinois opinions naming this issue, 2018–2022
2 sentences

2022Rather, 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.

13
Hinthorn v. Roland's of Bloomington, Inc.green
ill · 1988 · cited in 2 Illinois opinions naming this issue, 1992–2007
2 sentences

2007Hinthorn 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.

12
Balla v. Gambro, Inc.green
ill · 1991 · cited in 2 Illinois opinions naming this issue, 1992–1994
12
Beacham v. Walkergreen
ill · 2008 · cited in 1 Illinois opinions naming this issue, 2022–2022
11
People v. McCartygreen
ill · 2006 · cited in 1 Illinois opinions naming this issue, 2020–2020
11
Buckner v. Atlantic Plant Maintenance, Inc.green
ill · 1998 · cited in 1 Illinois opinions naming this issue, 2000–2000
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 (30)

CaseCitedYears
People v. Walsh green
illappct · 2016
2 sentences

2025“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)

62021–2025
Wieseman v. Kienstra, Inc. green
illappct · 1992
2 sentences

1998A 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.

41996–1998
In re Matter of Chance H. green
illappct · 2019
2 sentences

2024Nonetheless, 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 .

22024–2024
People v. Sebby green
ill · 2017
2 sentences

2021People 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.

22020–2021
People v. Taylor green
ill · 2011
2 sentences

2016“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 .

22015–2016
People v. Taylor green
ill · 2011
2 sentences

2016“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 .

22015–2016
Krum v. Chicago National League Ball Club, Inc. green
illappct · 2006
2 sentences

2007Krum v. Chicago National League Ball Club, Inc., 365 Ill.

2007Krum v. Chicago National League Ball Club, Inc., 365 Ill.

22007–2007
Jacobson v. Knepper & Moga, P.C. green
ill · 1998
2 sentences

2004Jacobson , 185 Ill. 2d at 376 .

2004Jacobson, 185 Ill. 2d at 376 .

22004–2004
Paris v. Cherry Payment Systems, Inc. green
illappct · 1994
2 sentences

2003Paris v. Cherry Payment Systems, Inc. , 265 Ill.

2003Paris v. Cherry Payment Systems, Inc., 265 Ill.

22003–2003
People v. Keene green
ill · 1995
22003–2003
Ludwig v. C & a WALLCOVERINGS, INC. green
ilnd · 1990
21992–1994
People v. Hartfield green
ill · 2022
12025–2025
People v. Williams green
illappct · 2022
12025–2025
Turner v. Memorial Medical Center green
ill · 2009
12025–2025
People v. Johnson green
illappct · 2021
12023–2023
People v. Veach green
ill · 2017
12023–2023
People v. Miller green
illappct · 2014
12023–2023
Sweeney v. The City of Decatur green
illappct · 2017
12022–2022
People v. Coats green
ill · 2018
12021–2021
People v. Rebollar-Vergara green
illappct · 2019
12021–2021
People v. Lewis green
ill · 2009
12019–2019
People v. Belmont green
illappct · 2018
12018–2018
People v. Belknap green
illappct · 2013
12015–2015
Dowell v. Bitner green
illappct · 1995
12006–2006
Hindo v. University of Health Sciences/Chicago Medical School green
illappct · 1992
11994–1994
People v. Owens green
ill · 1984
11993–1993
People v. Pastorino green
ill · 1982
11993–1993
Hartlein v. Illinois Power Co. green
ill · 1992
11992–1992
Thomas v. Zamberletti green
illappct · 1985
11992–1992
Mae McEwen v. Delta Air Lines, Inc. green
ca7 · 1990
11992–1992

Statutes the citing opinions construe

IL § 720 ILCS 5/9-1 (14) IL § 720 ILCS 570/401 (10) IL § 725 ILCS 207/1 (10) IL § 55 ILCS 5/4-2002 (9) IL § 730 ILCS 5/5-4.5-25 (7) IL § 730 ILCS 5/5-4.5-50 (7) IL § 730 ILCS 5/5-8-1 (7) IL § 735 ILCS 5/2-615 (7) IL § 725 ILCS 207/5 (6) IL § 725 ILCS 5/115-10 (5) IL § 730 ILCS 5/5-5-3.1 (5) IL § 705 ILCS 405/2-18 (4)

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

IL 125 (1991–2026) RI 2 (2008–2011) ME 2 (2014–2014)

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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