two step analysis (Illinois) · Go Syfert
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two step analysis in Illinois

15 Illinois opinions name it 2 courts 1977–2026 7 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
DEP. OF MENTAL HEALTH & DEV. DIS. v. Civil Serv. Comm'ngreen
ill · 1981 · cited in 2 Illinois opinions naming this issue, 2015–2015
2 sentences

2015Department of Mental Health & Developmental Disabilities v. Civil Service Comm'n, 85 Ill. 2d 547, 550 (1981).

2015Department of Mental Health & Developmental Disabilities v. Civil Service Comm'n, 85 Ill. 2d 547, 550 (1981).

22
People v. Veseygreen
illappct · 2024 · cited in 1 Illinois opinions naming this issue, 2026–2026
1 sentence

2026According to the majority, a trial court must first determine whether the record contains sufficient evidence of excessive force. 2024 IL App (4th) 230401, ¶ 28 (majority opinion).

11
Ehlers v. Jackson County Sheriff's Merit Commissiongreen
ill · 1998 · cited in 1 Illinois opinions naming this issue, 2026–2026
1 sentence

2026Ehlers v. Jackson County Sheriff’s Merit Comm’n, 183 Ill. 2d 83, 89 (1998).

11
People v. Kinggreen
ill · 1977 · cited in 1 Illinois opinions naming this issue, 2025–2025
1 sentence

2025Same Physical Act ¶ 64 Pursuant to the one-act, one-crime doctrine a defendant cannot be convicted of multiple offenses “carved from the same physical act,” where the “act” is defined as “any overt or outward manifestation which will support a different offense.” People v. King, 66 Ill. 2d 551, 566 (1977). 24 To determine whether multiple convictions may properly be entered, courts must engage in a two- step analysis.

11
People v. Rodriguezgreen
ill · 1996 · cited in 1 Illinois opinions naming this issue, 2021–2021
1 sentence

2021People v. Rodriguez, 169 Ill. 2d 183, 186 (1996).

11
Minch v. Georgegreen
illappct · 2009 · cited in 1 Illinois opinions naming this issue, 2021–2021
1 sentence

2021Minch v. George, 395 Ill.

11
Kansas v. Hendricksgreen
scotus · 1997 · cited in 1 Illinois opinions naming this issue, 2018–2018
1 sentence

2018The first step “ascertain[s] whether the legislature meant the statute to establish ‘civil’ proceedings.” Kansas v. Hendricks, 521 U.S. 346, 361 (1997).

11
People v. Millergreen
ill · 2010 · cited in 1 Illinois opinions naming this issue, 2017–2017
1 sentence

2017See Miller, 238 Ill. 2d at 165 .

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 (8)

CaseCitedYears
People v. Patrick green
ill · 2009
1 sentence

2023Id. at 74-76 .

12023–2023
Heatherly v. Rodman & Renshaw, Inc. green
illappct · 1997
1 sentence

2021There was no express “determination” in that case that the public policy exception applied. ¶ 33 The court in Heatherly included more discussion of the exception, beginning with the two- step test used to determine if the award violated public policy. 287 Ill.

12021–2021
People v. Coats green
ill · 2018
1 sentence

2020People v. Coats, 2018 IL 121926, ¶ 12 .

12020–2020
People v. Nunez green
ill · 2010
1 sentence

2017Pursuant to our de novo review (Nunez, 236 Ill. 2d at 493 ), we will apply this two- step analysis to the offenses of home invasion and residential burglary. ¶ 26 First, we must determine whether the conduct by which defendant committed these two offenses consisted of “precisely the same physical act” as opposed to multiple physical acts.

12017–2017
Merrifield v. Illinois State Police Merit Board green
illappct · 1997
1 sentence

2014Merrifield v. Illinois State Police Merit Board, 294 Ill.

12014–2014
Siwek v. POLICE BD. OF CITY OF CHICAGO green
illappct · 2007
1 sentence

2011Siwek v. Police Board, 374 Ill.

12011–2011
People v. Bridgeforth green
ill · 1972
2 sentences

1977(People v. Bridgeforth (1972), 51 Ill. 2d 52, 63 , 281 N.E.2d 617, 623 ; People v. Hairston (1970), 46 Ill. 2d 348 , 263 N.E.2d 840 .) Thus, the trial court’s discretion is measured by a two step test, namely, the testimony sought to be presented must be material to the case, and the defendant must not have been at fault in the violation of the order excluding the witnesses.

1977(People v. Bridgeforth (1972), 51 Ill. 2d 52, 63 , 281 N.E.2d 617, 623 ; People v. Hairston (1970), 46 Ill. 2d 348 , 263 N.E.2d 840 .) Thus, the trial court’s discretion is measured by a two step test, namely, the testimony sought to be presented must be material to the case, and the defendant must not have been at fault in the violation of the order excluding the witnesses.

11977–1977
The People v. Hairston green
ill · 1970
2 sentences

1977(People v. Bridgeforth (1972), 51 Ill. 2d 52, 63 , 281 N.E.2d 617, 623 ; People v. Hairston (1970), 46 Ill. 2d 348 , 263 N.E.2d 840 .) Thus, the trial court’s discretion is measured by a two step test, namely, the testimony sought to be presented must be material to the case, and the defendant must not have been at fault in the violation of the order excluding the witnesses.

1977(People v. Bridgeforth (1972), 51 Ill. 2d 52, 63 , 281 N.E.2d 617, 623 ; People v. Hairston (1970), 46 Ill. 2d 348 , 263 N.E.2d 840 .) Thus, the trial court’s discretion is measured by a two step test, namely, the testimony sought to be presented must be material to the case, and the defendant must not have been at fault in the violation of the order excluding the witnesses.

11977–1977

Where else courts name it

TX 120 (1978–2026) IN 34 (1981–2020) CT 32 (1986–2024) OH 23 (1990–2025) LA 22 (1985–2024) WA 22 (2005–2025) PA 21 (1976–2025) CA 20 (2001–2026) NJ 16 (1987–2026) IL 15 (1977–2026) DE 14 (1986–2024) MN 12 (1990–2024) DC 11 (1978–2019) AL 10 (1989–2016) CO 8 (1987–2025) FL 8 (1994–2025) MO 8 (1980–2019) AZ 7 (1985–2023) WI 6 (1978–2021) HI 6 (1993–2020) GA 5 (1979–2025) ME 5 (2002–2022) NC 5 (1992–2024) MD 5 (1998–2026) IA 4 (1981–2023) UT 3 (1991–1993) OR 3 (1986–2020) NV 3 (2017–2024) ID 3 (2020–2025) OK 3 (1991–2007) MA 3 (2023–2024) WY 3 (2009–2014) TN 3 (1998–2026) NY 2 (2008–2010) ND 2 (1999–2011) AK 2 (1974–1986) NE 2 (1983–2017) MI 2 (1978–2024) NM 2 (1979–2009) VA 2 (1990–2005) KS 2 (2018–2025) MS 2 (2005–2007)

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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