abandoned claim (Illinois) · Go Syfert
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abandoned claim in Illinois

11 Illinois opinions name it 2 courts 2008–2025 5 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. Hendersongreen
ill · 2013 · cited in 2 Illinois opinions naming this issue, 2018–2018
2 sentences

2018See Henderson, 2013 IL 114040, ¶ 15 . ¶ 31 For example, defendant argues that Beckman did not have probable cause to believe that his vehicle contained evidence of criminal activity based on Beckman’s observation that defendant dropped something between the driver’s seat and the door.

2018See Henderson , 2013 IL 114040 , ¶ 15, 370 Ill.Dec. 804 , 989 N.E.2d 192 . ¶ 31 For example, defendant argues that Beckman did not have probable cause to believe that his vehicle contained evidence of criminal activity based on Beckman's observation that defendant dropped something between the driver's seat and the door.

22
People v. Nichollsgreen
ill · 1978 · cited in 2 Illinois opinions naming this issue, 2016–2016
2 sentences

2016As part of our judgment, we grant the State’s request that defendant be assessed $50 as costs for this appeal. 55 ILCS 5/4-2002(a) (West 2014); see also People v. Nicholls, 71 Ill. 2d 166, 179 (1978). ¶ 42 Affirmed. - 16 -

2016As part of our judgment, we grant the State’s request that defendant be assessed $50 as costs for this appeal. 55 ILCS 5/4-2002(a) (West 2014); see also People v. Nicholls, 71 Ill. 2d 166, 179 (1978). ¶ 42 Affirmed. -9-

22
Dealy v. United Statesgreen
scotus · 1894 · cited in 1 Illinois opinions naming this issue, 2025–2025
1 sentence

2025Petitioner provides the principle as set forth by the United States Supreme Court more than 100 years ago in Dealy v. United States, 152 U.S. 539, 542 (1894), that a nolle prosequi “leaves the prosecution just as though no such count had ever been inserted in the indictment.” ¶ 120 Petitioner also cites the first appellate district majority’s comments in Smith, 2021 IL App (1st) 200984, ¶ 25 , that, “[a]bsent the refiling of the abandoned claim or a motion to vacate the nolle prosequi [citation], the State cannot pursue and thus has no ability to obtain a finding of guilt on an abandoned claim

11
People v. Greengreen
illappct · 2024 · cited in 1 Illinois opinions naming this issue, 2025–2025
1 sentence

2025Petitioner provides the principle as set forth by the United States Supreme Court more than 100 years ago in Dealy v. United States, 152 U.S. 539, 542 (1894), that a nolle prosequi “leaves the prosecution just as though no such count had ever been inserted in the indictment.” ¶ 120 Petitioner also cites the first appellate district majority’s comments in Smith, 2021 IL App (1st) 200984, ¶ 25 , that, “[a]bsent the refiling of the abandoned claim or a motion to vacate the nolle prosequi [citation], the State cannot pursue and thus has no ability to obtain a finding of guilt on an abandoned claim

11
People v. Bewgreen
ill · 2008 · cited in 1 Illinois opinions naming this issue, 2024–2024
1 sentence

2024As such, Carpenter’s ineffective assistance of counsel claim is “ ‘better suited to collateral proceedings.’ ” Id. ¶ 29 (quoting People v. Veach, 2017 IL 120649, ¶ 46 (noting that ineffective assistance of counsel claims may be better suited to collateral proceedings “when the record is incomplete or inadequate for resolving the claim”)); Bew, 228 Ill. 2d at 134 (same). ¶ 65 Because Carpenter’s conviction should be affirmed, I respectfully dissent. - 24 - No. 1-22-0970 People v. Carpenter, 2024 IL App (1st) 220970 Decision Under Review: Appeal from the Circuit Court of Cook County, No. 18-CR-8

11
People v. Williamsongreen
illappct · 2018 · cited in 1 Illinois opinions naming this issue, 2024–2024
2 sentences

2024See People v. Williamson, 2018 IL App (3d) 150828, ¶ 30 (declining to reach the merits of defendant’s ineffective assistance of counsel claim because the record was “insufficient to determine whether the abandoned claim would have been successful had it been pursued at the suppression hearing”).

2024As such, Carpenter’s ineffective assistance of counsel claim is “ ‘better suited to collateral proceedings.’ ” Id. ¶ 29 (quoting People v. Veach, 2017 IL 120649, ¶ 46 (noting that ineffective assistance of counsel claims may be better suited to collateral proceedings “when the record is incomplete or inadequate for resolving the claim”)); Bew, 228 Ill. 2d at 134 (same). ¶ 65 Because Carpenter’s conviction should be affirmed, I respectfully dissent. - 24 - No. 1-22-0970 People v. Carpenter, 2024 IL App (1st) 220970 Decision Under Review: Appeal from the Circuit Court of Cook County, No. 18-CR-8

11
People v. Veachgreen
ill · 2017 · cited in 1 Illinois opinions naming this issue, 2024–2024
1 sentence

2024As such, Carpenter’s ineffective assistance of counsel claim is “ ‘better suited to collateral proceedings.’ ” Id. ¶ 29 (quoting People v. Veach, 2017 IL 120649, ¶ 46 (noting that ineffective assistance of counsel claims may be better suited to collateral proceedings “when the record is incomplete or inadequate for resolving the claim”)); Bew, 228 Ill. 2d at 134 (same). ¶ 65 Because Carpenter’s conviction should be affirmed, I respectfully dissent. - 24 - No. 1-22-0970 People v. Carpenter, 2024 IL App (1st) 220970 Decision Under Review: Appeal from the Circuit Court of Cook County, No. 18-CR-8

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 (4)

CaseCitedYears
People v. Smith green
illappct · 2021
2 sentences

2025Petitioner provides the principle as set forth by the United States Supreme Court more than 100 years ago in Dealy v. United States, 152 U.S. 539, 542 (1894), that a nolle prosequi “leaves the prosecution just as though no such count had ever been inserted in the indictment.” ¶ 120 Petitioner also cites the first appellate district majority’s comments in Smith, 2021 IL App (1st) 200984, ¶ 25 , that, “[a]bsent the refiling of the abandoned claim or a motion to vacate the nolle prosequi [citation], the State cannot pursue and thus has no ability to obtain a finding of guilt on an abandoned claim

2022The court cited Hughes, 2012 IL 112817, ¶¶ 24-25 , as does petitioner here, and explained that “[a]bsent the refiling of the abandoned claim or a motion to vacate the nolle prosequi [citation], the State cannot pursue and thus has no ability to obtain a finding of guilt on an abandoned claim.” (Emphasis in original.) Smith, 2021 IL App (1st) 200984, ¶ 25 .

32022–2025
People v. Hughes green
ill · 2013
2 sentences

2022The court cited Hughes, 2012 IL 112817, ¶¶ 24-25 , as does petitioner here, and explained that “[a]bsent the refiling of the abandoned claim or a motion to vacate the nolle prosequi [citation], the State cannot pursue and thus has no ability to obtain a finding of guilt on an abandoned claim.” (Emphasis in original.) Smith, 2021 IL App (1st) 200984, ¶ 25 .

2022The court cited Hughes, 2012 IL 112817 , ¶¶ 24- 25, as does petitioner here, and explained that “[a]bsent the refiling of the abandoned claim or a motion to vacate the nolle prosequi *** the State cannot pursue and thus has no ability to obtain a finding of guilt on an abandoned claim.” (Emphasis in original.) Smith, 2021 IL App (1st) 200984, ¶ 25 .

32021–2022
People Ex Rel. Madison Chemical Corp. v. Gurrie green
illappct · 1964
2 sentences

2008Madison Chemical Corp., 52 Ill.

2008Madison Chemical Corp., 52 Ill.

22008–2008
People v. Carpenter green
illappct · 2024
1 sentence

2024As such, Carpenter’s ineffective assistance of counsel claim is “ ‘better suited to collateral proceedings.’ ” Id. ¶ 29 (quoting People v. Veach, 2017 IL 120649, ¶ 46 (noting that ineffective assistance of counsel claims may be better suited to collateral proceedings “when the record is incomplete or inadequate for resolving the claim”)); Bew, 228 Ill. 2d at 134 (same). ¶ 65 Because Carpenter’s conviction should be affirmed, I respectfully dissent. - 24 - No. 1-22-0970 People v. Carpenter, 2024 IL App (1st) 220970 Decision Under Review: Appeal from the Circuit Court of Cook County, No. 18-CR-8

12024–2024

Statutes the citing opinions construe

IL § 735 ILCS 5/2-702 (4) IL § 720 ILCS 5/24-1.6 (3) IL § 735 ILCS 5/2-1401 (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

PA 21 (1971–2024) IL 11 (2008–2025) TX 11 (1956–2024) MO 9 (2008–2020) LA 8 (1944–2016) TN 7 (2012–2018) NM 5 (2003–2026) WI 5 (1972–2008) FL 4 (1938–2005) NJ 4 (1954–1978) NY 4 (1907–2002) IA 3 (1939–1994) MD 3 (1993–2022) AL 3 (1979–1998) NC 3 (1993–2025) CT 3 (1999–2016) MA 2 (1983–1995) KS 2 (2018–2018) MI 2 (1986–1992) AR 2 (1983–1996) OH 2 (1984–2026) OR 2 (1975–2001) CA 2 (1990–2023)

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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