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13 Illinois opinions name it 1 courts 1991–2025 4 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.
| Case | Followed | Cited |
|---|---|---|
In Re JEMYgreen2 sentences2002App. 3d 389, 391 , 682 N.E.2d 451, 452 (1997), this court applied the Tufte holding to an admission to a probation violation and held that, following a probation revocation hearing, the filing of a motion to reconsider and compliance with the requirements of Rule 604(d) are unnecessary before taking an appeal. 2000App. 3d 389, 390-91 , 682 N.E.2d 451, 452 (1997), concluded that an admission to a probation violation, as occurred in this case, did not require compliance with Rule 604(d) (145 Ill. 2d R. 604(d)). | 3 | 3 |
People v. Westley A.F.green2 sentences2025Id. ¶ 21 Thus, in these cases, an admission to a probation violation results in the court having discretion to choose from among a range of available penalties, and due process requires that probationer understand the available sentencing range that will apply if he admits to the violation. 2025See id. at 796-97 ; People v. Curry, 2019 IL App (3d) 160783, ¶ 23 ; People v. Bailey, 2021 IL App (1st) 190439, ¶¶ 17, 27-29 . | 2 | 2 |
People v. Hallgreen2 sentences2007Rule 402A codifies the requirements of due process in an admission to a probation violation as set forth in Hall, 198 Ill. 2d at 181 . 210 Ill. 2d R. 402A, Committee Comments, at ccxvii. 2007Rule 402A codifies the requirements of due process in an admission to a probation violation as set forth in Hall, 198 Ill. 2d at 181 . 210 Ill. 2d R. 402A, Committee Comments, at ccxvii. | 1 | 3 |
People v. Baileygreen1 sentence2025See id. at 796-97 ; People v. Curry, 2019 IL App (3d) 160783, ¶ 23 ; People v. Bailey, 2021 IL App (1st) 190439, ¶¶ 17, 27-29 . | 1 | 1 |
People v. Enochgreen1 sentence2021But the State directs our attention to the general rule, stated in People v. Enoch, 122 Ill. 2d 176, 186 (1988), that “[b]oth a trial objection and a written post-trial motion raising [an] issue are required for alleged errors that could have been raised during trial.” (Emphases omitted.) We agree with Mr. Bailey that -4- this requirement is not applicable where, as here, the claim is that the trial court failed to give proper admonitions before accepting an admission to a probation violation in return for an agreed-upon sentence. ¶ 20 In People v. Curry, 2019 IL App (3d) 160783, ¶ 1 , as here | 1 | 1 |
People v. Harrisgreen1 sentence2020Although an admission to a probation violation must be voluntary, “only the minimum requirements of due process must be followed in a probation revocation proceeding.” People v. Harris, 392 Ill. | 1 | 1 |
People v. Tuftegreen1 sentence2009See 210 Ill. 2d R. 605(a)(1); see generally Tufte, 165 Ill. 2d 66 . | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Illinois. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
People v. Curry
green
2 sentences2021We agree with Mr. Bailey that this requirement is not applicable where, as here, the claim is that the trial court failed to give proper admonitions before accepting an admission to a probation violation in return for an agreed-upon sentence. -6- No. 1-19-0439 ¶ 20 In People v. Curry, 2019 IL App (3d) 160783, ¶ 1 , as here, the defendant appealed the revocation of his probation and his subsequent sentence of imprisonment on the basis that the trial judge failed to admonish him in substantial compliance with Rule 402A before accepting his admission to a probation violation. 2021But the State directs our attention to the general rule, stated in People v. Enoch, 122 Ill. 2d 176, 186 (1988), that “[b]oth a trial objection and a written post-trial motion raising [an] issue are required for alleged errors that could have been raised during trial.” (Emphases omitted.) We agree with Mr. Bailey that -4- this requirement is not applicable where, as here, the claim is that the trial court failed to give proper admonitions before accepting an admission to a probation violation in return for an agreed-upon sentence. ¶ 20 In People v. Curry, 2019 IL App (3d) 160783, ¶ 1 , as here | 3 | 2021–2025 |
People v. Whitfield
green
2 sentences2021“To so hold,” the court concluded, “would place the onus on the defendant to ensure his own admonishment in accord with due process.” Id. ¶ 22 We agree with the decisions of our court in Curry and Westley A.F. that the holding in -7- No. 1-19-0439 Whitfield is equally applicable when the court accepts an admission to a probation violation. 2021“To so hold,” the court concluded, “would place the onus on the defendant to ensure his own admonishment in accord with due process.” Id. ¶ 22 We agree with the decisions of our court in Curry and Westley A.F. that the holding in Whitfield is equally applicable when the court accepts an admission to a probation violation. | 2 | 2021–2021 |
People v. Dennis
green
2 sentences2007In turn, Hall (and, consequently, Rule 402A, by implication) was interpreted in People v. Dennis, 354 Ill. 2007In turn, Hall (and, consequently, Rule 402A, by implication) was interpreted in People v. Dennis, 354 Ill. | 2 | 2007–2007 |
People v. Davis
neutral
1 sentence2003To support his contention that all five cases should be remanded, the minor cites People v. Davis, 298 Ill. | 1 | 2003–2003 |
People v. Pier
green
1 sentence1991In People v. Pier ( 51 Ill. 2d at 99 ), our supreme court has held that, when an admission rests in any significant way upon a promise or agreement of a prosecutor so the same can be said to be part of the inducement or consideration, the promise must be fulfilled. | 1 | 1991–1991 |
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.
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.