Gates standard (Illinois) · Go Syfert
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Gates standard in Illinois

15 Illinois opinions name it 2 courts 1984–2026 3 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 (7)

CaseFollowedCited
United States v. Keith Williamsgreen
ca8 · 1993 · cited in 3 Illinois opinions naming this issue, 2008–2009
2 sentences

2009Corroboration of the Information In United States v. Fulgham, 143 F.3d 399, 401 (8th Cir. 1998), quoting United States v. Williams, 10 F.3d 590, 593 (8th Cir. 1993), the court wrote that “ ‘[^Information may be sufficiently reliable to support a probable[-]cause finding if the person providing the information has a track record of supplying reliable information, or if it is corroborated by independent evidence.’ ” On the facts of that case, the Fulgham court concluded that “the information given by the first informant was corroborated with specific, consistent details provided by the second in

2008Corroboration of the Information In United States v. Fulgham, 143 F.3d 399, 401 (8th Cir. 1998), quoting United States v. Williams, 10 F.3d 590, 593 (8th Cir. 1993), the court wrote that “ ‘[information may be sufficiently reliable to support a probable[-]cause finding if the person providing the information has a track record of supplying reliable information, or if it is corroborated by independent evidence.’ ” On the facts of that case, the Fulgham court concluded that “the information given by the first informant was corroborated with specific, consistent details provided by the second inf

33
United States v. Mambu Fulghamgreen
ca8 · 1998 · cited in 3 Illinois opinions naming this issue, 2008–2009
2 sentences

2009Corroboration of the Information In United States v. Fulgham, 143 F.3d 399, 401 (8th Cir. 1998), quoting United States v. Williams, 10 F.3d 590, 593 (8th Cir. 1993), the court wrote that “ ‘[^Information may be sufficiently reliable to support a probable[-]cause finding if the person providing the information has a track record of supplying reliable information, or if it is corroborated by independent evidence.’ ” On the facts of that case, the Fulgham court concluded that “the information given by the first informant was corroborated with specific, consistent details provided by the second in

2008Corroboration of the Information In United States v. Fulgham, 143 F.3d 399, 401 (8th Cir. 1998), quoting United States v. Williams, 10 F.3d 590, 593 (8th Cir. 1993), the court wrote that “ ‘[information may be sufficiently reliable to support a probable[-]cause finding if the person providing the information has a track record of supplying reliable information, or if it is corroborated by independent evidence.’ ” On the facts of that case, the Fulgham court concluded that “the information given by the first informant was corroborated with specific, consistent details provided by the second inf

33
People v. Exlinegreen
ill · 1983 · cited in 2 Illinois opinions naming this issue, 2006–2006
2 sentences

2006See People v. Exline, 98 Ill. 2d 150 (1983) (upholding the warrant under either the AguilarSpinelli test or the Gates totality-of-the-circumstances test); but see Exline, 98 Ill. 2d at 157-58 (Goldenhersh, J., dissenting, joined by Simon, J.) (noting that this court is “not required to blindly follow the action taken by the Supreme Court in determining the standards applicable under our own constitution,” and favoring retention of the Aguilar-Spinelli test under the Illinois Constitution).

2006See People v. Exline, 98 Ill. 2d 150 (1983) (upholding the warrant under either the AguilarSpinelli test or the Gates totality-of-the-circumstances test); but see Exline, 98 Ill. 2d at 157-58 (Goldenhersh, J., dissenting, joined by Simon, J.) (noting that this court is “not required to blindly follow the action taken by the Supreme Court in determining the standards applicable under our own constitution,” and favoring retention of the Aguilar-Spinelli test under the Illinois Constitution).

22
Illinois v. Gatesgreen
scotus · 1983 · cited in 3 Illinois opinions naming this issue, 1984–2026
2 sentences

2026Since the confidential source provided information that was accurate and confirmed by law enforcement with regard to the defendant, it was more likely that the information provided by the confidential source regarding the defendant’s illegal activities was also accurate. ¶ 47 Concerning the observations by the law enforcement officers, the question is not whether the activities observed are innocent or incriminating, but “whether the actions of the suspects, whatever their nature, give rise to an inference that the informant is credible and that he obtained his information in a reliable manner

2026Since the confidential source provided information that was accurate and confirmed by law enforcement with regard to the defendant, it was more likely that the information provided by the confidential source regarding the defendant’s illegal activities was also accurate. ¶ 47 Concerning the observations by the law enforcement officers, the question is not whether the activities observed are innocent or incriminating, but “whether the actions of the suspects, whatever their nature, give rise to an inference that the informant is credible and that he obtained his information in a reliable manner

13
People v. Tislergreen
ill · 1984 · cited in 3 Illinois opinions naming this issue, 1985–2026
2 sentences

2026Since the confidential source provided information that was accurate and confirmed by law enforcement with regard to the defendant, it was more likely that the information provided by the confidential source regarding the defendant’s illegal activities was also accurate. ¶ 47 Concerning the observations by the law enforcement officers, the question is not whether the activities observed are innocent or incriminating, but “whether the actions of the suspects, whatever their nature, give rise to an inference that the informant is credible and that he obtained his information in a reliable manner

2026Since the confidential source provided information that was accurate and confirmed by law enforcement with regard to the defendant, it was more likely that the information provided by the confidential source regarding the defendant’s illegal activities was also accurate. ¶ 47 Concerning the observations by the law enforcement officers, the question is not whether the activities observed are innocent or incriminating, but “whether the actions of the suspects, whatever their nature, give rise to an inference that the informant is credible and that he obtained his information in a reliable manner

13
People v. Veachgreen
ill · 2017 · cited in 1 Illinois opinions naming this issue, 2026–2026
1 sentence

2026See People v. Veach, 2017 IL 120649, ¶ 47 (noting petitioners do not forfeit ineffective assistance claims that depend on facts not in record). ¶ 58 The requisite science might also support an as-applied claim under the proportionate penalties clause.

11
People v. Gatesgreen
illappct · 2023 · cited in 1 Illinois opinions naming this issue, 2025–2025
1 sentence

2025In Justice Coghlan’s partial dissent, she concluded that the majority’s reasoning was speculative, and she cited our supreme court’s admonition that “ ‘under - 14 - no circumstances can conjecture constitute the sole basis for a claim of prejudice.’ ” Gates, 2023 IL App (1st) 211422, ¶ 91 (Coghlan, J., dissenting) (quoting People v. Hannon, 48 Ill. 2d 462 (1971)).

11

Distinguished, questioned or overruled (1)

CaseNegativeCited
People v. Exlinegreen
ill · 1983 · cited in 2 Illinois opinions naming this issue, 2006–2006
2 sentences

2006See People v. Exline, 98 Ill. 2d 150 (1983) (upholding the warrant under either the AguilarSpinelli test or the Gates totality-of-the-circumstances test); but see Exline, 98 Ill. 2d at 157-58 (Goldenhersh, J., dissenting, joined by Simon, J.) (noting that this court is “not required to blindly follow the action taken by the Supreme Court in determining the standards applicable under our own constitution,” and favoring retention of the Aguilar-Spinelli test under the Illinois Constitution).

2006See People v. Exline, 98 Ill. 2d 150 (1983) (upholding the warrant under either the AguilarSpinelli test or the Gates totality-of-the-circumstances test); but see Exline, 98 Ill. 2d at 157-58 (Goldenhersh, J., dissenting, joined by Simon, J.) (noting that this court is “not required to blindly follow the action taken by the Supreme Court in determining the standards applicable under our own constitution,” and favoring retention of the Aguilar-Spinelli test under the Illinois Constitution).

22

Also cited on this issue (9)

CaseCitedYears
People v. Spencer green
ill · 2025
1 sentence

2026Jurisdiction ¶ 43 The State also asserts that Gates’s claim “contradicts” the terms of the supervisory order and “triggers an important jurisdictional concern.” None exists. ¶ 44 The supervisory order directs us to “consider the effect of [its] opinion in People v. Spencer, 2025 IL 130015 ,” on our analysis of trial counsel’s performance: “whether *** trial counsel was ineffective for failing to argue that [Gates]’s sentence violates the proportionate penalties clause of the Illinois Constitution and determine if a different result is warranted.” Gates, No. 130271 (Ill.

12026–2026
People v. Miller green
ill · 2002
1 sentence

2026In the supplemental briefing, Gates concedes the first fails after Spencer but insists on the second: “As Spencer makes clear, the fact that Gates’[s] sentence is not a de facto life sentence in no way prohibits him from raising an as-applied proportionate penalties challenge at a new sentencing hearing. *** [T]rial counsel was ineffective for not advocating for a lesser sentence under the proportionate penalties clause[.]” -6- ¶ 38 The State’s waiver argument collapses Gates’s two claims into one claim dependent on a de facto life sentence and labels Gates’s focus in the supplemental briefing

12026–2026
The PEOPLE v. Hannon green
ill · 1971
1 sentence

2025In Justice Coghlan’s partial dissent, she concluded that the majority’s reasoning was speculative, and she cited our supreme court’s admonition that “ ‘under - 14 - no circumstances can conjecture constitute the sole basis for a claim of prejudice.’ ” Gates, 2023 IL App (1st) 211422, ¶ 91 (Coghlan, J., dissenting) (quoting People v. Hannon, 48 Ill. 2d 462 (1971)).

12025–2025
People v. Hieber green
illappct · 1994
2 sentences

1998People v. Hieber, 258 Ill.

1998People v. Hieber, 258 Ill.

11998–1998
Jain v. Northwest Community Hospital green
illappct · 1978
1 sentence

1988App. 3d 420, 425 , 385 N.E.2d 108 ), they maintain that a judicial review of Dr. Gates’ claim is limited by the common law writ of certiorari.

11988–1988
People v. Ross green
illappct · 1985
2 sentences

1986(People v. Ross (1985), 133 Ill.

1986(People v. Ross (1985), 133 Ill.

11986–1986
People v. Loveless green
illappct · 1980
2 sentences

1985He cites People v. Loveless (1980), 80 Ill.

1985He cites People v. Loveless (1980), 80 Ill.

11985–1985
People v. Reynolds green
ill · 1983
2 sentences

1984Ed. 2d 721 , 104 S. Ct. 2085 ), we must scrutinize the record facts under a Gates analysis in order to ascertain whether the trial judge committed manifest error in refusing to suppress the objectionable evidence, warranting a reversal (People v. Reynolds (1983), 94 Ill. 2d 160, 165 , 445 N.E.2d 766, 769 ).

1984Ed. 2d 721 , 104 S. Ct. 2085 ), we must scrutinize the record facts under a Gates analysis in order to ascertain whether the trial judge committed manifest error in refusing to suppress the objectionable evidence, warranting a reversal (People v. Reynolds (1983), 94 Ill. 2d 160, 165 , 445 N.E.2d 766, 769 ).

11984–1984
Massachusetts v. Upton green
scotus · 1984
2 sentences

1984Ed. 2d 721 , 104 S. Ct. 2085 ), we must scrutinize the record facts under a Gates analysis in order to ascertain whether the trial judge committed manifest error in refusing to suppress the objectionable evidence, warranting a reversal (People v. Reynolds (1983), 94 Ill. 2d 160, 165 , 445 N.E.2d 766, 769 ).

1984Ed. 2d 721 , 104 S. Ct. 2085 ), we must scrutinize the record facts under a Gates analysis in order to ascertain whether the trial judge committed manifest error in refusing to suppress the objectionable evidence, warranting a reversal (People v. Reynolds (1983), 94 Ill. 2d 160, 165 , 445 N.E.2d 766, 769 ).

11984–1984

Statutes the citing opinions construe

IL § 720 ILCS 570/401 (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

TX 31 (1984–2017) IL 15 (1984–2026) PA 13 (1998–2026) NY 10 (1985–1989) CA 9 (1902–2021) ID 8 (1967–1992) GA 8 (1978–2023) FL 8 (1986–2006) UT 8 (1985–1993) MD 8 (1984–2007) MS 7 (1985–2026) CO 7 (1986–1998) CT 7 (1985–2010) TN 6 (1989–2025) KY 6 (2014–2026) IA 6 (1976–1992) WY 5 (2010–2026) VT 5 (1987–2009) MT 5 (1983–2001) MN 5 (1984–2002) OK 4 (1987–1992) MA 4 (1984–2001) KS 3 (2003–2007) AL 3 (1985–2007) AZ 2 (1991–2015) NH 2 (1986–1988) OH 2 (1988–2008) IN 2 (2010–2018) MI 2 (1984–1993) RI 2 (2001–2021) LA 2 (1984–1984) NJ 2 (1986–1987) WV 2 (1986–1987) SD 2 (2000–2004) ME 2 (1993–1996) HI 2 (2011–2011)

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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