facial vagueness challenge (Illinois) · Go Syfert
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facial vagueness challenge in Illinois

14 Illinois opinions name it 2 courts 1987–2024 1 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
People v. Izzogreen
ill · 2001 · cited in 5 Illinois opinions naming this issue, 2004–2004
2 sentences

2004Regardless of the State's assertion of the *524 proper test for a facial vagueness challenge, the trial court's order did not discuss or acknowledge the first amendment facial vagueness standard, nor did it find the statute "incapable of any valid application" (see In re R.C., 195 Ill.2d at 299, 253 Ill.Dec. 699 , 745 N.E.2d 1233 ; Izzo, 195 Ill.2d at 112 , 253 Ill.Dec. 425 , 745 N.E.2d 548 ).

2004Regardless of the State's assertion of the *524 proper test for a facial vagueness challenge, the trial court's order did not discuss or acknowledge the first amendment facial vagueness standard, nor did it find the statute "incapable of any valid application" (see In re R.C., 195 Ill.2d at 299, 253 Ill.Dec. 699 , 745 N.E.2d 1233 ; Izzo, 195 Ill.2d at 112 , 253 Ill.Dec. 425 , 745 N.E.2d 548 ).

35
City of Chicago v. Moralesgreen
scotus · 1999 · cited in 4 Illinois opinions naming this issue, 2012–2024
2 sentences

2024The Wilson court also noted that: “The Constitution tolerates a lesser degree of vagueness in enactments with criminal rather than civil penalties and specifically those without a scienter requirement because the consequences of imprecision are more severe. [Citation.] In order to succeed in a facial vagueness challenge, as opposed to an as-applied challenge, the vagueness must ‘permeate[ ] the text of such a law.’ ” Id. ¶ 23 (quoting City of Chicago v. Morales, 527 U.S. 41, 55 (1999) (opinion of Stevens, J., joined by Souter and Ginsburg, JJ.)). ¶ 135 Defendant here asserts that section 11-23

2018The Wilson court also noted: “The Constitution tolerates a lesser degree of vagueness in enactments with criminal rather than civil penalties and specifically those without a scienter requirement because the consequences of imprecision are more severe. [Citation.] In order to succeed in a facial vagueness challenge, as opposed to an as- applied challenge, the vagueness must ‘permeate[ ] the text of such a law.’ ” Id. ¶ 23 (quoting City of Chicago v. Morales, 527 U.S. 41, 55 (1999) (opinion of Stevens, J., joined by Souter and Ginsburg, JJ.)) . ¶ 30 The plaintiffs have challenged the Ethics Ord

34
People v. Holtgreen
illappct · 1995 · cited in 3 Illinois opinions naming this issue, 2004–2004
2 sentences

2004See People v. Izzo, 195 Ill. 2d 109, 112 (2001) (a defendant cannot challenge facial vagueness of statute not impheating first amendment freedoms unless statute is incapable of any valid application); Holt, 271 Ill.

2004See People v. Izzo, 195 Ill.2d 109, 112 , 253 Ill.Dec. 425 , 745 N.E.2d 548 (2001) (a defendant cannot challenge facial vagueness of statute not implicating first amendment freedoms unless statute is incapable of any valid application); Holt, 271 Ill.App.3d at 1026 , 208 Ill.Dec. 515 , 649 N.E.2d 571 (it is only when such statute is incapable of any valid application that it is unconstitutionally vague).

23
People v. Einodergreen
ill · 2004 · cited in 2 Illinois opinions naming this issue, 2020–2020
2 sentences

2020People v. Einoder, 209 Ill. 2d 443, 451 (2004); cf. Johnson v. United States, 576 U.S. ___ , ___, 135 S. Ct. 2551, 2555, 2557-58, 2561 (2015) (finding that, regardless of whether the statute was vague in all applications, it was unconstitutionally vague where it required courts to consider how a crime is ordinarily committed, rather than the specific facts of the crime or the elements of the crime); see also United States v. Cook, 970 F.3d 866, 877 (7th Cir. 2020) (finding “Johnson did not alter the general rule that a defendant whose conduct is clearly prohibited by a statute cannot be the on

2020People v. Einoder, 209 Ill. 2d 443, 451 (2004); cf. Johnson v. United States, 576 U.S. 591, 593, 596-98, 603 (2015) (finding that regardless of whether the statute was vague in all applications, it was unconstitutionally vague where it required courts to consider how a crime is ordinarily committed, rather than the specific facts of the crime or the elements of the crime); see also United States v. Cook, 2020 WL 4782067 , * at 3, 5, 7, __ F.3d. __, __ (7th Cir. 2020) (finding “Johnson did not alter the general rule that a defendant whose conduct is clearly prohibited by a statute cannot be the

22
Johnson v. United Statesgreen
scotus · 2015 · cited in 2 Illinois opinions naming this issue, 2020–2020
2 sentences

2020People v. Einoder, 209 Ill. 2d 443, 451 (2004); cf. Johnson v. United States, 576 U.S. ___ , ___, 135 S. Ct. 2551, 2555, 2557-58, 2561 (2015) (finding that, regardless of whether the statute was vague in all applications, it was unconstitutionally vague where it required courts to consider how a crime is ordinarily committed, rather than the specific facts of the crime or the elements of the crime); see also United States v. Cook, 970 F.3d 866, 877 (7th Cir. 2020) (finding “Johnson did not alter the general rule that a defendant whose conduct is clearly prohibited by a statute cannot be the on

2020People v. Einoder, 209 Ill. 2d 443, 451 (2004); cf. Johnson v. United States, 576 U.S. 591, 593, 596-98, 603 (2015) (finding that regardless of whether the statute was vague in all applications, it was unconstitutionally vague where it required courts to consider how a crime is ordinarily committed, rather than the specific facts of the crime or the elements of the crime); see also United States v. Cook, 2020 WL 4782067 , * at 3, 5, 7, __ F.3d. __, __ (7th Cir. 2020) (finding “Johnson did not alter the general rule that a defendant whose conduct is clearly prohibited by a statute cannot be the

22
In Re RCgreen
ill · 2001 · cited in 2 Illinois opinions naming this issue, 2004–2004
2 sentences

2004Regardless of the State's assertion of the *524 proper test for a facial vagueness challenge, the trial court's order did not discuss or acknowledge the first amendment facial vagueness standard, nor did it find the statute "incapable of any valid application" (see In re R.C., 195 Ill.2d at 299, 253 Ill.Dec. 699 , 745 N.E.2d 1233 ; Izzo, 195 Ill.2d at 112 , 253 Ill.Dec. 425 , 745 N.E.2d 548 ).

2004Regardless of the State's assertion of the *524 proper test for a facial vagueness challenge, the trial court's order did not discuss or acknowledge the first amendment facial vagueness standard, nor did it find the statute "incapable of any valid application" (see In re R.C., 195 Ill.2d at 299, 253 Ill.Dec. 699 , 745 N.E.2d 1233 ; Izzo, 195 Ill.2d at 112 , 253 Ill.Dec. 425 , 745 N.E.2d 548 ).

12
United States v. Blair Cookgreen
ca7 · 2020 · cited in 1 Illinois opinions naming this issue, 2020–2020
1 sentence

2020People v. Einoder, 209 Ill. 2d 443, 451 (2004); cf. Johnson v. United States, 576 U.S. ___ , ___, 135 S. Ct. 2551, 2555, 2557-58, 2561 (2015) (finding that, regardless of whether the statute was vague in all applications, it was unconstitutionally vague where it required courts to consider how a crime is ordinarily committed, rather than the specific facts of the crime or the elements of the crime); see also United States v. Cook, 970 F.3d 866, 877 (7th Cir. 2020) (finding “Johnson did not alter the general rule that a defendant whose conduct is clearly prohibited by a statute cannot be the on

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 (9)

CaseCitedYears
People v. Curtis green
illappct · 2011
2 sentences

2020Curtis, 407 Ill.

2020Curtis, 407 Ill.

22020–2020
Pooh-Bah Enterprises, Inc. v. County of Cook green
ill · 2009
2 sentences

2012Pooh-Bah Enterprises, Inc., 232 Ill.2d at 492 , 328 Ill.Dec. 892 , 905 N.E.2d 781 .

2012Pooh-Bah Enterprises, Inc., 232 Ill.2d at 492 , 328 Ill.Dec. 892 , 905 N.E.2d 781 .

22012–2012
People v. Greco green
ill · 2003
2 sentences

2004"In cases * * * that do not involve first amendment freedoms, due process is satisfied if: (1) the statute's prohibitions are sufficiently definite, when measured by common understanding and practices, to give a person of ordinary intelligence fair warning as to what conduct is prohibited, and (2) the statute provides sufficiently definite standards for law enforcement officers and triers of fact that its application does not depend merely on their private conceptions." Greco, 204 Ill.2d at 416 , 274 Ill.Dec. 73 , 790 N.E.2d 846 .

2004"In cases * * * that do not involve first amendment freedoms, due process is satisfied if: (1) the statute's prohibitions are sufficiently definite, when measured by common understanding and practices, to give a person of ordinary intelligence fair warning as to what conduct is prohibited, and (2) the statute provides sufficiently definite standards for law enforcement officers and triers of fact that its application does not depend merely on their private conceptions." Greco, 204 Ill.2d at 416 , 274 Ill.Dec. 73 , 790 N.E.2d 846 .

22004–2004
Hoffman Estates v. Flipside, Hoffman Estates, Inc. green
scotus · 1982
2 sentences

1995Normally, a facial vagueness challenge will be upheld only if the statute is impermissibly vague in all of its applications. ( Village of Hoffman Estates v. Flipside, Hoffman Estates, Inc. (1982), 455 U.S. 489, 495 , 102 S.Ct. 1186, 1191 , 71 L.Ed.2d 362, 369 .) The United States Supreme Court has also recognized, however, that the standard of precision required of a statute is higher where, as here, the statute imposes criminal penalties.

1995Normally, a facial vagueness challenge will be upheld only if the statute is impermissibly vague in all of its applications. ( Village of Hoffman Estates v. Flipside, Hoffman Estates, Inc. (1982), 455 U.S. 489, 495 , 102 S.Ct. 1186, 1191 , 71 L.Ed.2d 362, 369 .) The United States Supreme Court has also recognized, however, that the standard of precision required of a statute is higher where, as here, the statute imposes criminal penalties.

21987–1995
Hill v. Colorado green
scotus · 2000
1 sentence

2024The Wilson court also noted that: “The Constitution tolerates a lesser degree of vagueness in enactments with criminal rather than civil penalties and specifically those without a scienter requirement because the consequences of imprecision are more severe. [Citation.] In order to succeed in a facial vagueness challenge, as opposed to an as-applied challenge, the vagueness must ‘permeate[ ] the text of such a law.’ ” Id. ¶ 23 (quoting City of Chicago v. Morales, 527 U.S. 41, 55 (1999) (opinion of Stevens, J., joined by Souter and Ginsburg, JJ.)). ¶ 135 Defendant here asserts that section 11-23

12024–2024
Ward v. Rock Against Racism green
scotus · 1989
1 sentence

2018The Wilson court also noted: “The Constitution tolerates a lesser degree of vagueness in enactments with criminal rather than civil penalties and specifically those without a scienter requirement because the consequences of imprecision are more severe. [Citation.] In order to succeed in a facial vagueness challenge, as opposed to an as- applied challenge, the vagueness must ‘permeate[ ] the text of such a law.’ ” Id. ¶ 23 (quoting City of Chicago v. Morales, 527 U.S. 41, 55 (1999) (opinion of Stevens, J., joined by Souter and Ginsburg, JJ.)) . ¶ 30 The plaintiffs have challenged the Ethics Ord

12018–2018
Kolender v. Lawson green
scotus · 1983
2 sentences

1995That consideration has, at times, led the court "to invalidate a criminal statute on its face even when it could conceivably have had some valid application." Kolender, 461 U.S. at 359 n. 8, 103 S.Ct. at 1859 n. 8, 75 L.Ed.2d at 910 n. 8.

1995That consideration has, at times, led the court "to invalidate a criminal statute on its face even when it could conceivably have had some valid application." Kolender, 461 U.S. at 359 n. 8, 103 S.Ct. at 1859 n. 8, 75 L.Ed.2d at 910 n. 8.

11995–1995
People v. Cartalino green
illappct · 1982
2 sentences

1993The defendant in People v. Cartalino (1982), 111 Ill.App.3d 578 , 67 Ill.Dec. 426 , 444 N.E.2d 662 , made the same argument that defendant advances here, but the court rejected it, holding that: "Section 5-8-1(a)(1) of the Code * * * does not permit the court to impose a sentence of natural life solely on the basis of the seriousness of the offense committed * * * without regard to a defendant's rehabilitative potential. [Citation omitted.] In determining a proper sentence for any felony, including murder, factors in aggravation and mitigation must be considered * * *." ( Cartalino, *1234 111

1993The defendant in People v. Cartalino (1982), 111 Ill.

11993–1993
People v. Abernathy green
illappct · 1989
1 sentence

1993The defendant in People v. Cartalino (1982), 111 Ill.App.3d 578 , 67 Ill.Dec. 426 , 444 N.E.2d 662 , made the same argument that defendant advances here, but the court rejected it, holding that: "Section 5-8-1(a)(1) of the Code * * * does not permit the court to impose a sentence of natural life solely on the basis of the seriousness of the offense committed * * * without regard to a defendant's rehabilitative potential. [Citation omitted.] In determining a proper sentence for any felony, including murder, factors in aggravation and mitigation must be considered * * *." ( Cartalino, *1234 111

11993–1993

Where else courts name it

TX 50 (1987–2025) CA 37 (1985–2024) WA 18 (1990–2025) OR 16 (1982–2022) IL 14 (1987–2024) FL 13 (1994–2018) ID 11 (1986–2024) UT 11 (1990–2022) GA 10 (2007–2026) CT 9 (1994–2026) NJ 7 (1983–2021) OH 7 (1998–2024) CO 7 (1999–2025) NV 6 (1992–2017) IA 5 (1987–2018) NM 5 (2007–2020) MT 3 (1993–2002) WY 3 (2003–2007) MD 3 (2019–2026) WI 3 (1997–2025) NE 3 (1987–2002) MI 2 (1990–2005) NC 2 (2015–2026) PA 2 (2004–2023) HI 2 (2007–2015) MN 2 (1985–2006) VA 2 (2018–2024)

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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