method inquiry (Illinois) · Go Syfert
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method inquiry in Illinois

101 Illinois opinions name it 2 courts 1909–2026 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. Thompsongreen
ill · 2010 · cited in 11 Illinois opinions naming this issue, 2020–2025
2 sentences

2022July 1, 2012) (“The court’s method of inquiry shall provide each juror an opportunity to respond to specific questions concerning the principles set out in this section.” (emphasis added)); see also Thompson, 238 Ill. 2d at 607 (“The rule requires an opportunity for a response from each prospective juror on their understanding and acceptance of those principles.” (emphasis added)). ¶ 25 As the trial court complied with Rule 431(b), there has been no error.

2021The text of the rule then enumerates each of those principles: “(1) that the defendant is presumed innocent of the charge(s) against him or her; (2) that before a defendant can be convicted the State must prove the defendant - 18 - guilty beyond a reasonable doubt; (3) that the defendant is not required to offer any evidence on his or her own behalf; and (4) that if a defendant does not testify it cannot be held against him or her; however, no inquiry of a prospective juror shall be made into the defendant’s decision not to testify when the defendant objects.” Id. ¶ 68 Additionally, Rule 431(b

611
Board of Education of Community School District No. 1 v. Comptongreen
ill · 1988 · cited in 5 Illinois opinions naming this issue, 2014–2022
2 sentences

2022Board of Education of the City of Chicago, 2015 IL 118043, ¶ 20 ; Board of Education of Community School District No. 1, Coles County v. Compton, 123 Ill. 2d 216, 225-26 , 526 N.E.2d 149, 154 (1988). ¶ 24 B.

2022Board of Education of the City of Chicago, 2015 IL 118043, ¶ 20 ; Board of Education of Community School District No. 1, Coles County v. Compton, 123 Ill. 2d 216, 225-26 , 526 N.E.2d 149, 154 (1988). ¶ 24 B.

35
People v. Van De Rostynegreen
ill · 1976 · cited in 3 Illinois opinions naming this issue, 1999–2014
2 sentences

2014See People v. Van De Rostyne, 63 Ill. 2d 364, 366 (1976) (the method to challenge the constitutionality of a defendant’s arrest is through a motion to quash and suppress evidence). ¶ 50 The parties raise several concluding matters.

2014See People v. Van De Rostyne, 63 Ill. 2d 364, 366 (1976) (the method to challenge the constitutionality of a defendant's arrest is through a motion to quash and suppress evidence). ¶ 50 The parties raise several concluding matters.

33
People v. Zehrgreen
ill · 1984 · cited in 14 Illinois opinions naming this issue, 2000–2022
2 sentences

2022“The court’s method of inquiry shall provide each juror an opportunity to respond to specific questions concerning the principles set out in this section.” (Emphasis added.) The single “Committee Comment” that follows the statement of the rule reinforces its actual focus, observing: “The new language is intended to ensure compliance with the requirements of People v. Zehr, 103 Ill.2d 472 (1984).

2021The court's method of inquiry shall provide each juror an opportunity to respond to specific questions concerning the principles set out in this section.” Id. ¶ 91 These are Zehr admonitions and inquiries, so named after People v. Zehr, 103 Ill. 2d 472 (1984).

214
People v. Johnsongreen
ill · 2002 · cited in 2 Illinois opinions naming this issue, 2025–2026
2 sentences

2026“Manifest error is that which is ‘clearly evident, plain, and indisputable.’ ” People v. Johnson, 206 Ill. 2d 348, 360 (2002) (quoting People v. Ruiz, 177 Ill. 2d 368, 384-85 (1997)). ¶ 57 A trial court’s method of inquiry at a preliminary Krankel proceeding is flexible.

2025“Manifest error is that which is ‘clearly evident, plain, and indisputable.’ ” People v. Johnson, 206 Ill. 2d 348, 360 (2002) (quoting People v. Ruiz, 177 Ill. 2d 368, 384-85 (1997)). ¶ 80 A trial court’s method of inquiry at a preliminary Krankel proceeding is flexible.

22
People v. Ruizgreen
ill · 1997 · cited in 2 Illinois opinions naming this issue, 2025–2026
2 sentences

2026“Manifest error is that which is ‘clearly evident, plain, and indisputable.’ ” People v. Johnson, 206 Ill. 2d 348, 360 (2002) (quoting People v. Ruiz, 177 Ill. 2d 368, 384-85 (1997)). ¶ 57 A trial court’s method of inquiry at a preliminary Krankel proceeding is flexible.

2025“Manifest error is that which is ‘clearly evident, plain, and indisputable.’ ” People v. Johnson, 206 Ill. 2d 348, 360 (2002) (quoting People v. Ruiz, 177 Ill. 2d 368, 384-85 (1997)). ¶ 80 A trial court’s method of inquiry at a preliminary Krankel proceeding is flexible.

22
Niles Township High School District 219 v. Illinois Educational Labor Relations Boardgreen
illappct · 2007 · cited in 2 Illinois opinions naming this issue, 2015–2016
2 sentences

2016See Board of Education of Community School District No. 1, Coles County v. Compton, 123 Ill. 2d 216, 225-26 (1988); Niles Township High School District 219 v. Illinois Educational Labor Relations Board, 379 Ill.

2015See Board of Education of Community School District No. 1, Coles County v. Compton, 123 Ill. 2d 216, 225-26 (1988); Niles Township High School District 219 v. Illinois Educational Labor Relations Board, 379 Ill.

22
People v. Yusufgreen
illappct · 2011 · cited in 2 Illinois opinions naming this issue, 2011–2011
2 sentences

2011See People v. Yusuf, 409 Ill.App.3d 435, 438 , 351 Ill.Dec. 39 , 949 N.E.2d 1134 (2011) ("This court reviews de novo a trial court's compliance with a supreme court rule."). ¶ 38 2.

2011See People v. Yusuf, 409 Ill.App.3d 435, 438 , 351 Ill.Dec. 39 , 949 N.E.2d 1134 (2011) ("This court reviews de novo a trial court's compliance with a supreme court rule."). ¶ 38 2.

22
People v. Glaspergreen
ill · 2009 · cited in 2 Illinois opinions naming this issue, 2010–2010
2 sentences

2010See Glasper, 234 Ill.2d at 189 , 334 Ill.Dec. 575 , 917 N.E.2d *835 401 ("[t]he trial court committed error when it ignored our long-standing precedent and our rules by refusing to question the venire in accordance with Rule 431(b)(4)"); People v. Magallanes, 397 Ill.

2010See Glasper, 234 Ill.2d at 189 , 334 Ill.Dec. 575 , 917 N.E.2d *835 401 ("[t]he trial court committed error when it ignored our long-standing precedent and our rules by refusing to question the venire in accordance with Rule 431(b)(4)"); People v. Magallanes, 397 Ill.

22
People v. Yusufgreen
illappct · 2010 · cited in 2 Illinois opinions naming this issue, 2009–2010
2 sentences

2010See People v. Yusuf, 399 Ill.App.3d 817, 819-21 , 340 Ill.Dec. 424 , 928 N.E.2d 143, 146-47 (2010). 2.

2010See People v. Yusuf, 399 Ill.App.3d 817, 819-21 , 340 Ill.Dec. 424 , 928 N.E.2d 143, 146-47 (2010). 2.

22
People v. Mooregreen
illappct · 1999 · cited in 2 Illinois opinions naming this issue, 2003–2003
2 sentences

2003See 725 ILCS 5/114--12 (West 2000) ; People v. Moore , 307 Ill.

2003See 725 ILCS 5/114 — 12 (West 2000); People v. Moore, 307 Ill.

22
People v. Willhitegreen
illappct · 2010 · cited in 4 Illinois opinions naming this issue, 2017–2020
2 sentences

2020See Willhite, 399 Ill.

2020In People v. Willhite, 399 Ill.

14
People v. Wilmingtongreen
ill · 2013 · cited in 3 Illinois opinions naming this issue, 2018–2019
2 sentences

2019See People v. Wilmington, 2013 IL 112938, ¶ 26 . ¶ 37 Rule 431(b) provides that: “The court shall ask each potential juror, individually or in a group, whether that juror understands and accepts the following principles: (1) that the defendant is presumed innocent of the charge(s) against him or her; (2) that before a defendant can be convicted the State must prove the defendant guilty beyond a reasonable doubt; (3) that the defendant is not required to offer any evidence on his or her own behalf; and (4) that if a defendant does not testify it cannot be held against him or her; however, no in

2019The court’s method of inquiry shall provide each juror an opportunity to respond to specific questions concerning the principles set out in this section.” ¶ 10 In People v. Wilmington, 2013 IL 112938, ¶ 28 , the circuit court explained the Rule 431(b) principles to the venire, then inquired whether any member “ ‘disagree[d] with this fundamental principle of law?’ ” The supreme court found that question insufficient under Rule 431(b), writing: “While it may be arguable that the court’s asking for disagreement, and getting none, is equivalent to juror acceptance of the principles, the trial cou

13
People v. Boykinsgreen
ill · 2017 · cited in 2 Illinois opinions naming this issue, 2020–2023
2 sentences

2023If a substantial showing of a constitutional violation is established, "the petition proceeds to the third stage for an evidentiary hearing." People v. Harris, 224 Ill. 2d 115, 126 , (2007). ¶ 37 “The * * * Act provides a method to challenge a conviction or sentence based on a substantial violation of constitutional rights.” People v. Boykins, 2017 IL 121365, ¶ 9 (citing 725 ILCS 5/122-1(a)(1) (West 2018)).

2020The circuit court noted that this court’s order on direct appeal highlighted the trial court’s conclusion that “no reasonable person” could believe that V.S. was 17 years old “regardless of whether [defendant] believed it or not.” The circuit court then dismissed the petition, finding that the “issues were raised and ruled on by the Appellate Court.” On its half- sheet, the circuit court noted that the “issues were raised [and] ruled on by the Appellate Court *** and no new issues have been raised.” ¶ 38 On appeal, defendant initially contends that the circuit court erred in dismissing his pos

12
People v. Reedgreen
illappct · 2007 · cited in 2 Illinois opinions naming this issue, 2009–2009
2 sentences

2009May 1, 2007. “ ‘The supreme court rules are not merely suggestions to be complied with if convenient but rather obligations which the parties and the courts are required to follow.’ ” People v. Reed, 376 Ill.

2009May 1, 2007. "`The supreme court rules are not merely suggestions to be complied with if convenient but rather obligations which the parties and the courts are required to follow.'" People v. Reed, 376 Ill.App.3d 121, 125 , 314 Ill.Dec. 657 , 875 N.E.2d 167, 171 (2007), quoting Medow v. Flavin, 336 Ill.App.3d 20, 36 , 270 Ill.Dec. 174 , 782 N.E.2d 733, 746-47 (2002).

12
McKeiver v. Pennsylvaniagreen
scotus · 1971 · cited in 2 Illinois opinions naming this issue, 2002–2002
2 sentences

2002McKeiver v. Pennsylvania, 403 U.S. 528, 533 , 29 L.

2002McKeiver v. Pennsylvania, 403 U.S. 528, 533 , 29 L.

12
Haswell v. Powellgreen
ill · 1967 · cited in 1 Illinois opinions naming this issue, 2025–2025
11
Grant v. Rancourgreen
illappct · 2020 · cited in 1 Illinois opinions naming this issue, 2021–2021
11
FOREST PRESERVE DIST. OF DU PAGE v. Millergreen
illappct · 2003 · cited in 1 Illinois opinions naming this issue, 2015–2015
11
People Ex Rel. Department of Public Aid v. Smithgreen
ill · 2004 · cited in 1 Illinois opinions naming this issue, 2013–2013
11
People v. Suarezgreen
ill · 2007 · cited in 1 Illinois opinions naming this issue, 2010–2010
11
People v. Magallanesgreen
illappct · 2009 · cited in 1 Illinois opinions naming this issue, 2010–2010
11
Medow v. Flavingreen
illappct · 2002 · cited in 1 Illinois opinions naming this issue, 2009–2009
11
Kent v. United Statesgreen
scotus · 1966 · cited in 1 Illinois opinions naming this issue, 2002–2002
11
Rollins v. Ellwoodgreen
ill · 1990 · cited in 1 Illinois opinions naming this issue, 1991–1991
11
Fumarolo v. Chicago Board of Educationgreen
ill · 1990 · cited in 1 Illinois opinions naming this issue, 1991–1991
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 (40)

CaseCitedYears
People v. Fields green
illappct · 2013
2 sentences

2025However, the trial court’s method of inquiry is “somewhat flexible.” People v. Fields, 2013 IL App (2d) 120945 , ¶ 40.

2014Id. ¶ 30 We found the Krankel inquiry improper, stating: “Although a trial court’s method of inquiry at the Krankel hearing is somewhat flexible (by virtue of its ability to ask questions of the defendant, the defendant’s counsel, etc.), and we can envision a situation where the State may be asked to offer concrete and easily verifiable facts at the hearing, no case law suggests that the State should be an active participant during the preliminary inquiry.

92014–2025
People v. Belknap green
ill · 2014
2 sentences

2021People v. Belknap, 2014 IL 117094, ¶ 45 .

2020Rule 431(b) further states, “The court’s method of inquiry shall provide each juror an opportunity to respond to specific questions concerning the principles set out in this section.” Id. ¶ 69 We turn first to whether the trial court erred by asking about the four principles in compound form.

42020–2021
Board of Education of the City of Chicago v. Illinois Educational Labor Relations Board green
ill · 2015
2 sentences

2022Board of Education of the City of Chicago, 2015 IL 118043, ¶ 20 ; Board of Education of Community School District No. 1, Coles County v. Compton, 123 Ill. 2d 216, 225-26 , 526 N.E.2d 149, 154 (1988). ¶ 24 B.

2021App. 3d 395, 409 (1988) (Prairie State), for the proposition that “refusal to arbitrate an educational labor dispute does not constitute an unfair labor practice.” The School District notes that, as stated by our supreme court in Board of Education of the City of Chicago v. Illinois Educational Labor Relations Board, 2015 IL 118043, ¶ 20 , refusal to arbitrate is an appropriate method to challenge arbitrability. ¶ 58 We find these arguments are not meritorious.

22021–2022
People v. Wrencher green
illappct · 2011
2 sentences

2020People v. Wrencher, 2011 IL App (4th) 080619, ¶ 37 , 959 N.E.2d 693 . ¶ 42 In Thompson, 238 Ill. 2d at 607 , the supreme court found noncompliance with Rule 431(b) where the trial court failed to address one of the four Rule 431(b) principles and failed to ask prospective jurors whether they accepted another principle.

2020People v. Wrencher, 2011 IL App (4th) 080619, ¶ 37 , 959 N.E.2d 693 . ¶ 60 Here, defendant argues the trial court was required to address each Rule 431(b) principle “separately” and erred by “combining” the four principles “into a single statement on the law.” He cites Thompson to support that contention.

22020–2020
People v. Wrencher green
illappct · 2011
2 sentences

2020People v. Wrencher, 2011 IL App (4th) 080619, ¶ 37 , 959 N.E.2d 693 . ¶ 42 In Thompson, 238 Ill. 2d at 607 , the supreme court found noncompliance with Rule 431(b) where the trial court failed to address one of the four Rule 431(b) principles and failed to ask prospective jurors whether they accepted another principle.

2020People v. Wrencher, 2011 IL App (4th) 080619, ¶ 37 , 959 N.E.2d 693 . ¶ 60 Here, defendant argues the trial court was required to address each Rule 431(b) principle “separately” and erred by “combining” the four principles “into a single statement on the law.” He cites Thompson to support that contention.

22020–2020
People v. Radford green
ill · 2020
2 sentences

2020The court’s method of inquiry shall provide each juror an opportunity to respond to specific questions concerning the principles set out in this section.” Id.

2020The court’s method of inquiry shall provide each juror an opportunity to respond to specific questions concerning the principles set out in this section.” Id.

22020–2020
People v. Rinehart green
ill · 2012
2 sentences

2017“The court’s method of inquiry shall provide each juror an opportunity to respond to specific questions concerning the principles set out in [Rule 431(b)].” Id.

2017“The court’s method of inquiry shall provide each juror an opportunity to respond to specific questions concerning the principles set out in [Rule 431(b)].” Id.

22017–2017
People Ex Rel. O'Malley v. Village of Ford Heights green
illappct · 1994
2 sentences

2003O'Malley, 261 Ill.App.3d at 574-75 , 199 Ill.Dec. 52 , 633 N.E.2d 848 .

2003O’Malley, 261 Ill.

22003–2003
R. W. Sawant & Co. v. Allied Programs Corp. green
ill · 1986
2 sentences

2001Sawant, 111 Ill.2d at 309-10 , 95 Ill.Dec. 496 , 489 N.E.2d 1360 .

2001Sawant, 111 Ill.2d at 309-10 , 95 Ill.Dec. 496 , 489 N.E.2d 1360 .

22001–2001
Zaderaka v. Illinois Human Rights Commission green
ill · 1989
2 sentences

2001We analyze employment discrimination causes brought under the Illinois Human Rights Act, as is the instant one, according to the "framework set forth in United States Supreme Court decisions addressing claims under Title VII of the Civil Rights Act of 1964. " Lalvani v. Illinois Human Rights Comm'n , No. 1-99-3283, slip op. at 26 (July 31, 2001) (our Supreme Court, in Zaderaka , 131 Ill. 2d at 178 , adopted the Supreme Court's method of analysis); Livingston , 302 Ill.

2001App. 3d 774, 789 (2001) (our supreme court, in Zaderaka, 131 Ill. 2d at 178 , adopted the Supreme Court’s method of analysis); Livingston, 302 Ill.

22001–2001
Illinois J. Livingston Co. v. Human Rights Commission green
illappct · 1998
2 sentences

2001We analyze employment discrimination causes brought under the Illinois Human Rights Act, as is the instant one, according to the "framework set forth in United States Supreme Court decisions addressing claims under Title VII of the Civil Rights Act of 1964. " Lalvani v. Illinois Human Rights Comm'n , No. 1-99-3283, slip op. at 26 (July 31, 2001) (our Supreme Court, in Zaderaka , 131 Ill. 2d at 178 , adopted the Supreme Court's method of analysis); Livingston , 302 Ill.

2001App. 3d 774, 789 (2001) (our supreme court, in Zaderaka, 131 Ill. 2d at 178 , adopted the Supreme Court’s method of analysis); Livingston, 302 Ill.

22001–2001
People v. Andrews green
ill · 1992
2 sentences

1998The Illinois Supreme Court has held that “[t]he number of blacks stricken compared to the number of nonblacks stricken may reveal whether a disproportionate number of strikes was used to exclude blacks.” (Emphasis added.) Andrews, 146 Ill. 2d at 430 .

1998The Illinois Supreme Court has held that "[t]he number of blacks stricken compared to the number of nonblacks stricken may reveal whether a disproportionate number of strikes was used to exclude blacks." (Emphasis added.) Andrews , 146 Ill. 2d at 430 .

21998–1998
People v. Sandlin neutral
illappct · 2021
1 sentence

2025App. 3d 1094 (1992), and People v. Sandlin, 2021 IL App (5th) 190120 - U—that the exception where additional charges were included in or implied by the existing counts 5 also did not apply because the charging of four counts of child pornography in no way implied that there would be additional photographs supporting additional counts. ¶ 17 The State argued that Hiatt was inconsistent with the more recent Illinois Supreme Court decision in People v. Gooden, 189 Ill. 2d 209 (2000), which changed the method and analysis of this issue.

12025–2025
People v. Williams green
ill · 2003
1 sentence

2025The State also cited Williams, 204 Ill. 2d 191 , and noted that if several offenses were known to the proper prosecuting officer at the time of commencing the prosecution and were within the jurisdiction of a single court, they must be prosecuted in a single prosecution if they were based on the same act.

12025–2025
People v. Gooden green
ill · 2000
12025–2025
People v. Shanklin green
illappct · 1999
12023–2023
People v. Harris green
ill · 2007
12023–2023
People v. Birge green
ill · 2021
12022–2022
In re Marriage of Paris green
illappct · 2021
12021–2021
People v. Bloomingburg green
illappct · 2004
12021–2021
Doe v. Township High School District 211 green
illappct · 2015
12021–2021
People v. Sebby green
ill · 2017
12020–2020
Chicago Housing Authority v. Berkson green
ill · 1953
12015–2015
Caterpillar Tractor Co. v. Industrial Commission green
ill · 1989
12015–2015
People v. Moore green
ill · 2003
12013–2013
Hoglund v. State Farm Mutual Automobile Insurance green
ill · 1992
11996–1996
Duldulao v. Saint Mary of Nazareth Hospital Center green
ill · 1987
11991–1991
Kirk v. Michael Reese Hospital & Medical Center green
ill · 1987
11990–1990
Johnson v. Village of Libertyville green
illappct · 1986
11990–1990
State v. Wisconsin Employment Relations Commission green
wis · 1985
11988–1988
Oliver v. United States green
scotus · 1984
11985–1985
People v. King green
ill · 1977
11982–1982
Kokinis v. Kotrich green
ill · 1980
11980–1980
People v. Rossi green
ill · 1972
11975–1975
Kemeny v. Skorch green
illappct · 1959
11961–1961
The People v. Ney neutral
ill · 1932
11951–1951
People v. Sanculius green
illappct · 1936
11943–1943
People Ex Rel. Wangelin v. St. Louis Bridge Co. green
ill · 1934
11941–1941
People Ex Rel. Lax v. Ehler neutral
ill · 1933
11935–1935
People ex rel. Weber v. City of Spring Valley green
ill · 1889
11909–1909

Statutes the citing opinions construe

IL § 720 ILCS 5/9-1 (11) IL § 720 ILCS 5/12-3 (8) IL § 720 ILCS 5/12-4 (8) IL § 720 ILCS 5/12-3.05 (7) IL § 115 ILCS 5/14 (6) IL § 720 ILCS 5/12-3.2 (6) IL § 720 ILCS 5/24-1.2 (6) IL § 720 ILCS 570/401 (6) IL § 735 ILCS 5/2-1401 (6) IL § 115 ILCS 5/4 (5) IL § 720 ILCS 5/9-2 (5) IL § 735 ILCS 5/3-110 (5)

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

CT 126 (1942–2023) IL 101 (1909–2026) CA 87 (1928–2026) TX 73 (1972–2025) OH 61 (1957–2026) OR 46 (1962–2025) PA 42 (1935–2024) NY 34 (1892–2026) FL 31 (1935–2019) LA 28 (1923–2024) NC 27 (1916–2023) IN 27 (1972–2019) MA 26 (1936–2025) MO 26 (1913–2015) MI 25 (1974–2023) AL 25 (1923–2015) WA 25 (1967–2025) WI 23 (1953–2023) AZ 19 (1964–2025) NJ 17 (1845–2018) WV 14 (1955–2022) NE 14 (1950–2002) TN 13 (1972–2026) MN 12 (1985–2018) GA 11 (1936–2023) NV 10 (1996–2020) MD 10 (1971–2016) ND 9 (1975–2013) IA 9 (1980–2019) OK 8 (1943–2015) CO 8 (1982–2018) SD 7 (1958–2003) AR 7 (1915–2025) RI 7 (1976–2017) MT 6 (1930–2017) WY 6 (1965–1993) VT 6 (1935–2020) ME 5 (1981–2021) KY 5 (1915–2022) NM 5 (1991–2022) HI 4 (1952–2015) UT 4 (1985–2016) KS 3 (1923–2024) VA 3 (2005–2020) AK 2 (1984–1986) DE 2 (2009–2024) ID 2 (1991–1996) NH 2 (2016–2019) DC 2 (1992–2014)

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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