sufficiency of evidence test (Illinois) · Go Syfert
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sufficiency of evidence test in Illinois

18 Illinois opinions name it 2 courts 1998–2025 5 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 (3)

CaseFollowedCited
Kyles v. Whitleygreen
scotus · 1995 · cited in 9 Illinois opinions naming this issue, 1998–2018
2 sentences

2018The materiality inquiry “ ‘is not a sufficiency of evidence test’ ” (People v. Coleman, 183 Ill. 2d 366, 393 (1998) (quoting Kyles v. Whitley, 514 U.S. 419, 434 (1995))) and “a showing of materiality does not require demonstration by a preponderance that disclosure would have resulted ultimately in defendant’s acquittal.” Id.

2018The materiality inquiry “ ‘is not a sufficiency of evidence test’ ” (People v. Coleman, 183 Ill. 2d 366, 393 (1998) (quoting Kyles v. Whitley, 514 U.S. 419, 434 (1995))) and “a showing of materiality does not require demonstration by a preponderance that disclosure would have resulted ultimately in defendant’s acquittal.” Id.

39
People v. Batchelorgreen
ill · 1996 · cited in 2 Illinois opinions naming this issue, 1999–1999
2 sentences

1999People v. Batchelor, 171 Ill. 2d 367, 376 (1996).

1999People v. Batchelor , 171 Ill. 2d 367, 376 (1996).

22
People v. Colemangreen
ill · 1998 · cited in 3 Illinois opinions naming this issue, 2001–2018
2 sentences

2018The materiality inquiry “ ‘is not a sufficiency of evidence test’ ” (People v. Coleman, 183 Ill. 2d 366, 393 (1998) (quoting Kyles v. Whitley, 514 U.S. 419, 434 (1995))) and “a showing of materiality does not require demonstration by a preponderance that disclosure would have resulted ultimately in defendant’s acquittal.” Id.

2001The materiality determination “turns on whether, the ‘[g]overnment’s evidentiary suppression “undermines confidence in the outcome of the trial,” ’ which *** ‘is not a sufficiency of evidence test.’ ” Coleman, 183 Ill. 2d at 393 , quoting Kyles v. Whitley, 514 U.S. 419, 434 , 131 L.

13

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 (6)

CaseCitedYears
United States v. Bagley green
scotus · 1985
2 sentences

2001The materiality determination "turns on whether the `[government's evidentiary suppression "undermines confidence in the outcome of the trial,"` which * * * `is not a sufficiency of evidence test.'" Coleman, 183 Ill.2d at 393 , 233 Ill.Dec. 789 , 701 N.E.2d 1063 , quoting Kyles v. Whitley, 514 U.S. 419, 434 , 115 S.Ct. 1555, 1566 , 131 L.Ed.2d 490, 506 (1995), quoting Bagley, 473 U.S. at 678 , 105 S.Ct. at 3381 , 87 L.Ed.2d at 491 .

2001The materiality determination "turns on whether the `[government's evidentiary suppression "undermines confidence in the outcome of the trial,"` which * * * `is not a sufficiency of evidence test.'" Coleman, 183 Ill.2d at 393 , 233 Ill.Dec. 789 , 701 N.E.2d 1063 , quoting Kyles v. Whitley, 514 U.S. 419, 434 , 115 S.Ct. 1555, 1566 , 131 L.Ed.2d 490, 506 (1995), quoting Bagley, 473 U.S. at 678 , 105 S.Ct. at 3381 , 87 L.Ed.2d at 491 .

41998–2001
People v. Cline green
ill · 2022
2 sentences

2024However, as our supreme court explained in People v. Cline, 2022 IL 126383, ¶¶ 32-33 , a sufficiency of evidence analysis “must be limited to evidence actually admitted at trial, and judicial notice cannot be used to introduce new evidentiary material -9- No. 1-22-0575 not considered by the fact finder during its deliberations,” because, to conclude otherwise would “wholly ignore[ ] the role of a reviewing court” in examining a defendant’s guilt. ¶ 25 While defendant attempts to distinguish Cline on the basis that the supreme court there was considering a request to take judicial notice of sci

2023Cline, 2022 IL 126383, ¶¶ 32-33 . ¶ 46 That said, if the defendant believes that these documents unequivocally establish that, when the search warrant was executed, the apartment contained two bedrooms, instead of one, thereby impeaching the testimony of the two police officers, and giving more credence to Webster’s version of events, to such an extent that there is a reasonable probability that the outcome of his 9 These documents purport to include (1) a warranty deed from an online search of the Cook County Recorder of Deeds, (2) an MLS listing for the property, and (3) a 2019 YouTube video

32023–2024
People v. Appelgren green
illappct · 2007
2 sentences

2020Id. at 144 .

2020Id. at 144 .

22020–2020
People v. Smith green
illappct · 2004
2 sentences

2010Furthermore, “Materiality ‘is not a sufficiency of evidence test.’ ” Smith, 352 Ill.

2010Furthermore, “Materiality ‘is not a sufficiency of evidence test.’ ” Smith, 352 Ill.

22010–2010
People v. Lee green
ill · 2004
1 sentence

2025Lee, 213 Ill. 2d at 225 .

12025–2025
People v. Jackson green
ill · 2020
1 sentence

2025When a sufficiency of evidence claim is raised, “a reviewing court must determine whether, after 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.” People v. Jackson, 2020 IL 124112, ¶ 64 .

12025–2025

Statutes the citing opinions construe

IL § 720 ILCS 5/24-1.7 (3) IL § 720 ILCS 5/9-1 (3) IL § 725 ILCS 5/122-1 (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

LA 252 (1982–2025) CA 141 (1979–2026) OH 77 (1995–2025) PA 38 (1979–2025) IN 27 (1977–2024) TX 26 (1988–2023) CT 25 (1985–2024) IL 18 (1998–2025) NM 13 (1994–2026) WA 12 (2004–2025) DE 10 (1993–2023) IA 8 (1974–2025) NV 7 (2018–2021) MN 7 (1986–2016) WV 6 (1996–2020) OR 5 (2004–2014) MO 5 (1996–2024) WI 4 (2003–2021) UT 4 (1993–2021) KS 4 (2005–2022) FL 4 (1982–2022) MS 4 (2000–2019) NJ 3 (1988–2024) NC 3 (2022–2026) TN 3 (1988–2020) MD 3 (2002–2021) MI 3 (1992–2021) VA 2 (2002–2003) ID 2 (2021–2021)

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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