touchstone of Fourth Amendment analysis (Illinois) · Go Syfert
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touchstone of Fourth Amendment analysis in Illinois

13 Illinois opinions name it 2 courts 2003–2025 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.

Followed or applied (8)

CaseFollowedCited
Ohio v. Robinettegreen
scotus · 1996 · cited in 5 Illinois opinions naming this issue, 2015–2021
2 sentences

2021Reasonableness is the touchstone of fourth amendment analysis and “is measured in objective terms by examining the totality of the circumstances.” Ohio v. Robinette, 519 U.S. 33, 39 (1996).

2019Reasonableness, as a touchstone of fourth amendment analysis, “ ‘is measured in objective terms by examining the totality of the circumstances.’ ” Id. (quoting Ohio v. Robinette, 519 U.S. 33, 39 (1996)).

55
United States v. Brignoni-Poncegreen
scotus · 1975 · cited in 2 Illinois opinions naming this issue, 2011–2011
2 sentences

2011"Reasonableness" depends upon "a balance between the public interest and the individual's right to personal security free from arbitrary interference by law officers." United States v. Brignoni-Ponce, 422 U.S. 873, 878 , 95 S.Ct. 2574 , 45 L.Ed.2d 607 (1975).

2011"Reasonableness" depends upon "a balance between the public interest and the individual's right to personal security free from arbitrary interference by law officers." United States v. Brignoni-Ponce, 422 U.S. 873, 878 , 95 S.Ct. 2574 , 45 L.Ed.2d 607 (1975).

22
Pennsylvania v. Mimmsgreen
scotus · 1977 · cited in 2 Illinois opinions naming this issue, 2011–2011
2 sentences

2011Once it is determined that a search or seizure has taken place, in order to pass constitutional muster, it must be "reasonable." Indeed, the touchstone of fourth amendment analysis "is always `the reasonableness in all the circumstances of the particular governmental invasion of a citizen's personal security.'" Pennsylvania v. Mimms, 434 U.S. 106, 109 , 98 S.Ct. 330 , 54 L.Ed.2d 331 (1977) (quoting Terry, 392 U.S. at 19 , 88 S.Ct. 1868 ).

2011Once it is determined that a search or seizure has taken place, in order to pass constitutional muster, it must be "reasonable." Indeed, the touchstone of fourth amendment analysis "is always `the reasonableness in all the circumstances of the particular governmental invasion of a citizen's personal security.'" Pennsylvania v. Mimms, 434 U.S. 106, 109 , 98 S.Ct. 330 , 54 L.Ed.2d 331 (1977) (quoting Terry, 392 U.S. at 19 , 88 S.Ct. 1868 ).

22
United States v. Dennis Dayton Holtgreen
ca10 · 2001 · cited in 2 Illinois opinions naming this issue, 2003–2003
2 sentences

2003United States v. Holt, 264 F.3d 1215, 1220 (10th Cir. 2001).

2003United States v. Holt, 264 F.3d 1215, 1220 (10th Cir.2001).

22
Katz v. United Statesgreen
scotus · 1967 · cited in 1 Illinois opinions naming this issue, 2025–2025
1 sentence

2025The acts necessary to view the contents of the cabinet indicated that the contents were not plainly visible, and those acts constituted a warrantless -7- search. ¶ 19 A. Reasonable Expectation of Privacy ¶ 20 “The touchstone of Fourth Amendment analysis is whether a person has a ‘constitutionally protected reasonable expectation of privacy.’ ” California v. Ciraolo, 476 U.S. 207, 211 (1986) (quoting Katz v. United States, 389 U.S. 347, 360 (1967) (Harlan, J., concurring)).

11
California v. Ciraologreen
scotus · 1986 · cited in 1 Illinois opinions naming this issue, 2025–2025
1 sentence

2025The acts necessary to view the contents of the cabinet indicated that the contents were not plainly visible, and those acts constituted a warrantless -7- search. ¶ 19 A. Reasonable Expectation of Privacy ¶ 20 “The touchstone of Fourth Amendment analysis is whether a person has a ‘constitutionally protected reasonable expectation of privacy.’ ” California v. Ciraolo, 476 U.S. 207, 211 (1986) (quoting Katz v. United States, 389 U.S. 347, 360 (1967) (Harlan, J., concurring)).

11
Brigham City v. Stuartgreen
scotus · 2006 · cited in 1 Illinois opinions naming this issue, 2021–2021
1 sentence

2021King, 563 U.S. at 459 ; Brigham City v. Stuart, 547 U.S. 398, 403 (2006) (the touchstone of fourth amendment analysis always is “reasonableness”).

11
Michael J. Green and Cheryl Poulsen v. Marlo Butler, David Carroll, Mark Salsberrygreen
ca7 · 2005 · cited in 1 Illinois opinions naming this issue, 2007–2007
1 sentence

2007Accord Green v. Butler, 420 F.3d 689, 694 (7th Cir. 2005) (“The touchstone of Fourth Amendment inquiry is reasonableness, *** a standard measured in light of the totality of the circumstances and determined by balancing the degree to which a challenged action intrudes on an individual’s privacy and the degree to which the action promotes a legitimate government interest”).

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 (7)

CaseCitedYears
Terry v. Ohio green
scotus · 1968
2 sentences

2011Once it is determined that a search or seizure has taken place, in order to pass constitutional muster, it must be "reasonable." Indeed, the touchstone of fourth amendment analysis "is always `the reasonableness in all the circumstances of the particular governmental invasion of a citizen's personal security.'" Pennsylvania v. Mimms, 434 U.S. 106, 109 , 98 S.Ct. 330 , 54 L.Ed.2d 331 (1977) (quoting Terry, 392 U.S. at 19 , 88 S.Ct. 1868 ).

2011Once it is determined that a search or seizure has taken place, in order to pass constitutional muster, it must be "reasonable." Indeed, the touchstone of fourth amendment analysis "is always `the reasonableness in all the circumstances of the particular governmental invasion of a citizen's personal security.'" Pennsylvania v. Mimms, 434 U.S. 106, 109 , 98 S.Ct. 330 , 54 L.Ed.2d 331 (1977) (quoting Terry, 392 U.S. at 19 , 88 S.Ct. 1868 ).

22011–2011
People v. Lindsey green
ill · 2020
1 sentence

2025“Our analysis [of fourth amendment cases] begins and ends, therefore, with the question of whether the defendant has established a legitimate expectation of privacy in the place searched.” People v. Lindsey, 2020 IL 124289, ¶ 16 .

12025–2025
People v. Carter green
ill · 2021
1 sentence

2023People v. Carter, 2021 IL 125954, ¶ 22 . ¶ 20 A traffic stop constitutes a seizure of the person, and if the seizure violates the fourth amendment, any evidence the State obtains as a result of that violation is suppressible.

12023–2023
Kentucky v. King green
scotus · 2011
1 sentence

2021King, 563 U.S. at 459 ; Brigham City v. Stuart, 547 U.S. 398, 403 (2006) (the touchstone of fourth amendment analysis always is “reasonableness”).

12021–2021
People v. McDonough green
ill · 2010
2 sentences

2019Reasonableness, as a touchstone of fourth amendment analysis, “ ‘is measured in objective terms by examining the totality of the circumstances.’ ” Id. (quoting Ohio v. Robinette, 519 U.S. 33, 39 (1996)).

2019Reasonableness, as a touchstone of fourth amendment analysis, “ ‘is measured in objective terms by examining the totality of the circumstances.’ ” Id. (quoting Robinette, 519 U.S. at 39 ).

12019–2019
People v. Reedy green
illappct · 2015
1 sentence

2018Ohio v. Robinette, 519 U.S. 33, 39 (1996). ¶ 52 Although a police officer may stop and briefly detain a motorist when the officer has observed the motorist committing a traffic offense (People v. Abdur-Rahim, 2014 IL App (3d) 130558, ¶ 26 , 16 N.E.3d 903 ), the traffic stop can become unlawful “if it is prolonged beyond the time reasonably required to satisfy its initial purpose” (People v. Reedy, 2015 IL App (3d) 130955, ¶ 25 , 39 N.E.3d 318 ).

12018–2018
People v. Abdur-Rahim green
illappct · 2014
2 sentences

2018Ohio v. Robinette, 519 U.S. 33, 39 (1996). ¶ 52 Although a police officer may stop and briefly detain a motorist when the officer has observed the motorist committing a traffic offense (People v. Abdur-Rahim, 2014 IL App (3d) 130558, ¶ 26 , 16 N.E.3d 903 ), the traffic stop can become unlawful “if it is prolonged beyond the time reasonably required to satisfy its initial purpose” (People v. Reedy, 2015 IL App (3d) 130955, ¶ 25 , 39 N.E.3d 318 ).

2018Ohio v. Robinette, 519 U.S. 33, 39 (1996). ¶ 52 Although a police officer may stop and briefly detain a motorist when the officer has observed the motorist committing a traffic offense (People v. Abdur-Rahim, 2014 IL App (3d) 130558, ¶ 26 , 16 N.E.3d 903 ), the traffic stop can become unlawful “if it is prolonged beyond the time reasonably required to satisfy its initial purpose” (People v. Reedy, 2015 IL App (3d) 130955, ¶ 25 , 39 N.E.3d 318 ).

12018–2018

Statutes the citing opinions construe

IL § 720 ILCS 646/60 (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

CA 24 (1986–2024) IL 13 (2003–2025) MI 9 (1986–2026) OH 8 (2001–2016) NM 6 (1995–2023) IN 6 (2001–2009) FL 5 (1991–2014) CO 5 (1984–1996) WI 4 (2017–2026) TX 3 (2004–2024) ME 3 (2016–2018) NJ 3 (1990–2013) LA 2 (1986–1987) VA 2 (1997–2020) OR 2 (2026–2026) GA 2 (1991–2019) AR 2 (1992–2000)

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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