burden of proving defense (Illinois) · Go Syfert
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burden of proving defense in Illinois

94 Illinois opinions name it 3 courts 1907–2026 15 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 (18)

CaseFollowedCited
Van Meter v. Darien Park Dist.green
ill · 2003 · cited in 7 Illinois opinions naming this issue, 2006–2022
2 sentences

2022Van Meter, 207 Ill. 2d at 370 .

2021Van Meter v. Darien Park District, 207 Ill. 2d 359, 370 (2003). ¶ 15 At the outset, we note that the existence of a duty and the existence of an immunity are separate issues.

57
Lebron v. Gottlieb Memorial Hospitalgreen
ill · 2010 · cited in 5 Illinois opinions naming this issue, 2017–2022
2 sentences

2022Lebron v. Gottlieb Memorial Hospital, 237 Ill. 2d 217, 252 (2010); Bayview Loan Servicing, LLC v. Cornejo, 2015 IL App (3d) 140412, ¶ 12 .

2020Lebron v. Gottlieb Memorial Hospital, 237 Ill. 2d 217, 252 (2010).

45
People v. Herrongreen
ill · 2005 · cited in 4 Illinois opinions naming this issue, 2006–2023
2 sentences

2006Under the plain-error doctrine, defendant has the burden of proving an error occurred (see People v. Herron, 215 Ill. 2d 167, 187 , 830 N.E.2d 467, 480 (2005)) and thus had the burden of demonstrating the handcuff was visible to the jury.

2006Under the plain-error doctrine, defendant has the burden of proving an error occurred (see People v. Herron, 215 Ill. 2d 167, 187 , 830 N.E.2d 467, 480 (2005)) and thus had the burden of demonstrating the handcuff was visible to the jury.

34
People v. Smithgreen
illappct · 2003 · cited in 3 Illinois opinions naming this issue, 2017–2023
2 sentences

2023A violation of the terms of the conditions of discharge subjects the defendant to revocation and resentencing.730 ILCS 5/5- 6-4 (West 2020) (“If the court finds that the offender has violated a condition at any time prior to the expiration or termination of the period, it may continue him on the existing sentence, with or without modifying or enlarging the conditions, or may impose any other sentence that was available under Article 4.5 of Chapter V of this Code ***.”) -5- No. 1-22–0801 ¶ 24 At a hearing to revoke conditional discharge, the State has the burden of proving a violation by a prep

2018We find that the defense of necessity applied to defendant’s conduct in briefly possessing a stolen firearm to return it to the store, and the circuit court’s finding to the contrary was against the manifest weight of the evidence. ¶ 21 At a hearing on the State’s petition to revoke conditional discharge, the State has the burden of proving a violation of a condition of conditional discharge by a preponderance of the evidence. 730 ILCS 5/5-6-4(c) (West 2016). “[A] revocation of conditional discharge will be overturned only when it is contrary to the manifest weight of the evidence.” People v.

33
People v. Taubegreen
illappct · 1998 · cited in 2 Illinois opinions naming this issue, 2010–2010
2 sentences

2010"The determination to terminate probation rests within the discretion of the trial -12- 1-08-0870 court, and, unless the determination was against the manifest weight of the evidence, an appellate court will not disturb the trial court's ruling." People v. Taube, 299 Ill.

2010“The determination to terminate probation rests within the discretion of the trial court, and, unless the determination was against the manifest weight of the evidence, an appellate court will not disturb the trial court’s ruling.” People v. Taube, 299 Ill.

22
United States v. Alvin Omega Owensgreen
ca11 · 1988 · cited in 2 Illinois opinions naming this issue, 2006–2006
2 sentences

2006The United States Court of Appeals for the 11th Circuit held, under this insanity statute, “a federal criminal defendant is due a jury instruction on insanity when the evidence would allow a reasonable jury to find that insanity has been shown with convincing clarity.” United States v. Owens, 854 F.2d 432, 435 (11th Cir. 1988).

2006The United States Court of Appeals for the Eleventh Circuit held, under this insanity statute, “a federal criminal defendant is due a jury instruction on insanity when the evidence would allow a reasonable jury to find that insanity has been shown with convincing clarity.” United States v. Owens, 854 F.2d 432, 435 (11th Cir. 1988).

22
American National Bank & Trust Co. v. Village of Libertyvillegreen
illappct · 1995 · cited in 2 Illinois opinions naming this issue, 2001–2001
2 sentences

2001While it is true that defendants bear the burden of proving the doctrine applies (American National Bank & Trust Co. v. Village of Libertyville, 269 Ill.

2001While it is true that defendants bear the burden of proving the doctrine applies ( American National Bank & Trust Co. v. Village of Libertyville , 269 Ill.

22
People v. Howardgreen
illappct · 1990 · cited in 3 Illinois opinions naming this issue, 2007–2009
2 sentences

2009People v. Howard, 205 Ill.

2009People v. Howard, 205 Ill.App.3d 702, 708 , 151 Ill.Dec. 113 , 563 N.E.2d 1219 (1990); see People v. Reimolds, 92 Ill.2d 101, 106 , 65 Ill.Dec. 17 , 440 N.E.2d 872 (1982).

13
People v. Currygreen
illappct · 2013 · cited in 1 Illinois opinions naming this issue, 2026–2026
1 sentence

2026See id. ¶ 25 As the record shows respondents were aware their parental rights could be terminated, respondents have not proved they were denied due process and, thus, have not proved an error occurred.

11
Chicago Title & Trust Co. v. Illinois Merchants Trust Co.green
ill · 1928 · cited in 1 Illinois opinions naming this issue, 2025–2025
1 sentence

2025Contracts § 907 (Dec. 2024 Supp.); see also Chicago Title & Trust Co. v. Illinois Merchants’ Trust Co., 329 Ill. 334, 345 (1928) (“The claim that the contract was unfair was an affirmative defense, and the burden of proving that defense rested on [defendants-]appellants.”).

11
Insurance Benefit Group, Inc. v. Guarantee Trust Life Insurance Companygreen
illappct · 2017 · cited in 1 Illinois opinions naming this issue, 2025–2025
1 sentence

2025See Insurance Benefit Group, Inc. v. Guarantee Trust Life Insurance Co., 2017 IL App (1st) 162808, ¶ 44 . ¶ 34 Key to defendant’s appellate claims is proof she did not understand English to the extent she could meaningfully participate in the third-stage hearing or communicate with counsel in the presentation of her claims.

11
Willett v. Cessna Aircraft Co.green
illappct · 2006 · cited in 1 Illinois opinions naming this issue, 2025–2025
1 sentence

2025See, e.g., Willet v. Cessna Aircraft Co., 366 Ill.

11
Mendez v. City of Chicagogreen
illappct · 2023 · cited in 1 Illinois opinions naming this issue, 2023–2023
1 sentence

2023See Mendez v. City of Chicago, 2023 IL App (1st) 211513, ¶ 28 . 1 ¶ 15 On appeal, plaintiffs assert that neither the Charter nor the Series B Agreements required them to bring this action in Delaware.

11
People v. Reimoldsgreen
ill · 1982 · cited in 1 Illinois opinions naming this issue, 2009–2009
11
Estate of Rollins v. La Salle National Bankgreen
illappct · 1995 · cited in 1 Illinois opinions naming this issue, 1996–1996
11
In Re Estate of Milborngreen
illappct · 1984 · cited in 1 Illinois opinions naming this issue, 1996–1996
11
City of Chicago v. Joycegreen
ill · 1967 · cited in 1 Illinois opinions naming this issue, 1985–1985
11
Colucci v. Chicago Crime Commissiongreen
illappct · 1975 · cited in 1 Illinois opinions naming this issue, 1975–1975
11

Distinguished, questioned or overruled (1)

CaseNegativeCited
In Re Estate of Sewartgreen
illappct · 1995 · cited in 1 Illinois opinions naming this issue, 1996–1996
11

Also cited on this issue (61)

CaseCitedYears
Bayview Loan Servicing, LLC v. Cornejo green
illappct · 2015
2 sentences

2022Lebron v. Gottlieb Memorial Hospital, 237 Ill. 2d 217, 252 (2010); Bayview Loan Servicing, LLC v. Cornejo, 2015 IL App (3d) 140412, ¶ 12 .

2018Lebron v. Gottlieb Memorial Hospital , 237 Ill. 2d 217 , 252, 341 Ill.Dec. 381 , 930 N.E.2d 895 (2010) ; Bayview Loan Servicing, LLC v. Cornejo , 2015 IL App (3d) 140412 , ¶ 12, 395 Ill.Dec. 601 , 39 N.E.3d 68 .

42017–2022
Deutsche Bank National Trust v. Gilbert green
illappct · 2012
2 sentences

2018Gilbert , 2012 IL App (2d) 120164 , ¶ 15, 367 Ill.Dec. 665 , 982 N.E.2d 815 . ¶ 19 Typically, lack of standing to bring an action is an affirmative defense, and the burden of proving the defense is on the party asserting it.

2018Gilbert , 2012 IL App (2d) 120164 , ¶ 15, 367 Ill.Dec. 665 , 982 N.E.2d 815 . ¶ 19 Typically, lack of standing to bring an action is an affirmative defense, and the burden of proving the defense is on the party asserting it.

32017–2018
People v. Patterson green
ill · 2005
2 sentences

2016Id. ¶ 56 In this case, without the proper admission of the prior statement, defendant was prejudiced by the prosecutor's questioning of Lindsey where the prosecutor's questions insinuated that a robbery was planned, a robbery occurred, defendant initiated the robbery, and defendant was the gunman who shot and killed the store clerk.

2016Id. ¶ 56 In this case, without the proper admission of the prior statement, defendant was prejudiced by the prosecutor's questioning of Lindsey where the prosecutor's questions insinuated that a robbery was planned, a robbery occurred, defendant initiated the robbery, and defendant was the gunman who shot and killed the store clerk.

32016–2016
People v. Gwinn green
illappct · 1994
2 sentences

2016Thus, because the exception to the statute of limitations was an element of the State’s case, defendant did not forfeit the issue by failing to raise it in a pretrial motion and the State was not relieved of the burden of proving the exception at trial. ¶ 12 We distinguish the present situation from that in People v. Gwinn, 255 Ill.

2015Thus, because the exception to the statute of limitations was an element of the State’s case, defendant did not forfeit the issue by failing to raise it in a pretrial motion and the State was not relieved of the burden of proving the exception at trial. -4- 2015 IL App (2d) 140139 ¶ 12 We distinguish the present situation from that in People v. Gwinn, 255 Ill.

32015–2016
In Re Estate of Pohn green
illappct · 1966
2 sentences

2014In re Estate of Pohn, 67 Ill.

2014In re Estate of Pohn, 67 Ill.

31976–2014
People v. Price green
illappct · 1960
2 sentences

1971(People v. Price (2nd Dist. 1960), 24 Ill.App.2d 364 , 164 N.E.2d 528 ; People v. White (4th Dist. 1968), 93 Ill.App.2d 283 , 235 N.E.2d 393 .) The sentence to be imposed is for the original offense and not for the subsequent conduct.

1971(People v. Price (2nd Dist. 1960), 24 Ill.App.2d 364 , 164 N.E.2d 528 ; People v. White (4th Dist. 1968), 93 Ill.App.2d 283 , 235 N.E.2d 393 .) The sentence to be imposed is for the original offense and not for the subsequent conduct.

31965–1971
People v. Lutter green
illappct · 2015
2 sentences

2015Thus, because the exception to the statute of limitations was an element of the State’s case, defendant did not forfeit the issue by failing to raise it in a pretrial motion and the State was not relieved of the burden of proving the exception at trial. -4- 2015 IL App (2d) 140139 ¶ 12 We distinguish the present situation from that in People v. Gwinn, 255 Ill.

2015Thus, because the exception to the statute of limitations was an element of the State’s case, defendant did not forfeit the issue by failing to raise it in a pretrial motion and the State was not relieved of the burden of proving the exception at trial. -4- 2015 IL App (2d) 140139 ¶ 12 We distinguish the present situation from that in People v. Gwinn, 255 Ill.

22015–2015
Langenhorst v. Norfolk Southern Ry. Co. green
ill · 2006
2 sentences

2012Langenhorst, 219 Ill.2d at 444 , 302 Ill.Dec. 363 , 848 N.E.2d at 935 . ¶ 19 The defendant has the burden of proving the doctrine should be applied.

2012Langenhorst, 219 Ill.2d at 444 , 302 Ill.Dec. 363 , 848 N.E.2d at 935 . ¶ 19 The defendant has the burden of proving the doctrine should be applied.

22012–2012
Landmark Insurance Company v. NIP Group green
illappct · 2011
2 sentences

2012Langenhorst, 219 Ill.2d at 444 , 302 Ill.Dec. 363 , 848 N.E.2d at 935 ; Landmark American Insurance Co., 2011 IL App (1st) 101155, ¶ 50 , 356 Ill.Dec. 877 , 962 N.E.2d at 577 .

2012Langenhorst, 219 Ill.2d at 444 , 302 Ill.Dec. 363 , 848 N.E.2d at 935 ; Landmark American Insurance Co., 2011 IL App (1st) 101155, ¶ 50 , 356 Ill.Dec. 877 , 962 N.E.2d at 577 .

22012–2012
De Rosa v. Albert F. Amling Co. green
illappct · 1980
2 sentences

2007To determine whether or not the plaintiff was an employee of the defendant at the time of the occurrence, you must weigh the following factors: First, whether the defendant directed and controlled the work done by the plaintiff; Second, whether the defendant had the right to discharge the plaintiff; Third, whether the defendant furnished the materials used by the plaintiff; Fourth, whether the defendant controlled the manner in which the work was done by the plaintiff; Fifth, whether the plaintiff is paid on a time basis or by the job.’ ” De Rosa, 84 Ill.

2007To determine whether or not the plaintiff was an employee of the defendant at the time of the occurrence, you must weigh the following factors: First, whether the defendant directed and controlled the work done by the plaintiff; Second, whether the defendant had the right to discharge the plaintiff; Third, whether the defendant furnished the materials used by the plaintiff; Fourth, whether the defendant controlled the manner in which the work was done by the plaintiff; Fifth, whether the plaintiff is paid on a time basis or by the job.'" De Rosa, 84 Ill.App.3d at 74-75 , 39 Ill.Dec. 180 , 404

22007–2007
Deck v. Missouri green
scotus · 2005
2 sentences

2006Second, even if the handcuff was visible to the jury, the State has proved “ ‘beyond a reasonable doubt that the [shackling] error complained of did not contribute to the verdict obtained.’ ” Deck, 544 U.S. at 635 , 161 L.

2006Second, even if the handcuff was visible to the jury, the State has proved “ ‘beyond a reasonable doubt that the [shackling] error complained of did not contribute to the verdict obtained.’ ” Deck, 544 U.S. at 635 , 161 L.

22006–2006
Chapman v. California red
scotus · 1967
2 sentences

2006Chapman v. California, 386 U.S. 18, 24 , 17 L.

2006Chapman v. California, 386 U.S. 18, 24 , 17 L.

22006–2006
In re Sole neutral
ilclaimsct · 1976
2 sentences

1998In re Application of Sole (1976), 31 Ill.

1993In re Application of Sole (1976), 31 Ill.

21993–1998
People v. Staten green
ill · 1994
1 sentence

2023People v. Staten, 159 Ill. 2d 419 , 426 9 (1994); see also 725 ILCS 5/103-5(f) (West 2018) (stating that “[d]elay occasioned by the defendant shall temporarily suspend for the time of the delay the period within which a person shall be tried”).

12023–2023
People v. Jackson green
ill · 2022
1 sentence

2023Id. § 6-2(e).

12023–2023
People v. Welling green
illappct · 2021
1 sentence

2022Id. (citing 720 ILCS 5/6-4, 6-2(e) (West 2012)).

12022–2022
People v. Butler green
illappct · 2015
1 sentence

2022People v. Butler, 2015 IL App (1st) 131870, ¶ 33 .

12022–2022
Travelers Personal Insurance Company v. Edwards green
illappct · 2016
12016–2016
GPS USA, Inc. v. Performance Powdercoating green
illappct · 2015
12015–2015
City of Peoria v. Heim green
illappct · 1992
12000–2000
In re Bavido neutral
ilclaimsct · 1991
11998–1998
In re Schaffer neutral
ilclaimsct · 1989
11996–1996
People v. Davis green
illappct · 1991
11995–1995
People v. Hamm green
ill · 1992
11993–1993
People v. Beard green
ill · 1974
11993–1993
First Security Bank v. Bawoll green
illappct · 1983
11993–1993
City of Chicago v. Chiagouris neutral
illappct · 1968
11992–1992
Village of Northbrook v. Cannon green
illappct · 1978
11992–1992
People v. Bouchard green
illappct · 1989
11991–1991
People v. Bales green
ill · 1985
11990–1990
People v. Upton green
ill · 1986
11990–1990
Rambert v. Industrial Commission green
illappct · 1985
11990–1990
People v. Fosdick green
illappct · 1988
11990–1990
Vestal v. Industrial Commission green
ill · 1981
11990–1990
Rex Chainbelt Inc. v. Borg-Warner Corporation, Rex Chainbelt Inc. v. Carman Industries, Inc. green
ca7 · 1973
11989–1989
Wallace v. Industrial Commission neutral
ill · 1983
11988–1988
National Labor Relations Board v. West Point Manufacturing Company (Lanett Mill) green
ca5 · 1957
11987–1987
National Labor Relations Board v. Great Dane Trailers, Inc. green
scotus · 1967
11987–1987
Miller Electric Manufacturing Co., Inc. v. National Labor Relations Board neutral
ca7 · 1959
11987–1987
Brown v. State neutral
ilclaimsct · 1980
11987–1987

Statutes the citing opinions construe

IL § 735 ILCS 5/2-615 (7) IL § 735 ILCS 5/2-619.1 (7) IL § 735 ILCS 5/2-619 (6) IL § 720 ILCS 5/9-1 (5) IL § 730 ILCS 5/5-6-4 (4) IL § 745 ILCS 10/4-102 (4) IL § 720 ILCS 5/12-5 (3) IL § 720 ILCS 5/24-3.1 (3) IL § 720 ILCS 5/3-6 (3) IL § 725 ILCS 5/106-2.5 (3) IL § 745 ILCS 10/1-101.1 (3) IL § 815 ILCS 505/1 (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

TX 223 (1908–2026) CA 185 (1920–2026) LA 167 (1939–2025) PA 140 (1919–2026) IN 101 (1922–2024) IL 94 (1907–2026) WA 86 (1942–2025) GA 81 (1940–2026) OH 79 (1957–2025) MO 66 (1929–2025) TN 61 (1985–2025) MI 57 (1948–2025) VA 54 (1918–2024) CT 53 (1982–2026) NY 46 (1882–2025) CO 46 (1938–2026) FL 37 (1944–2025) WV 37 (1919–2026) IA 34 (1902–2025) AZ 31 (1957–2023) NC 29 (1970–2026) AR 29 (1966–2023) WI 28 (1959–2025) MD 27 (2005–2024) AL 25 (1902–2016) MS 24 (1922–2023) NJ 23 (1951–2025) MA 22 (1908–2026) MN 21 (1979–2018) OR 21 (1896–2024) ID 18 (1944–2026) KS 17 (1918–2026) NM 17 (1971–2025) ND 17 (1915–2023) ME 14 (1969–2025) SC 12 (1917–2019) MT 12 (1969–2022) NE 11 (1876–2013) RI 11 (1978–2022) SD 10 (1929–2017) DE 10 (1977–2026) UT 10 (1896–2025) KY 9 (1951–2024) VT 8 (1960–2020) OK 7 (1912–1971) NH 6 (1967–2009) WY 6 (2004–2024) DC 5 (1990–2020) HI 5 (1981–2020) AK 4 (1983–1996) NV 3 (1982–2020) VI 2 (1977–2014)

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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