course-of-investigation exception (Illinois) · Go Syfert
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course-of-investigation exception in Illinois

11 Illinois opinions name it 1 courts 2013–2026 6 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 (9)

CaseFollowedCited
People v. Gachogreen
ill · 1988 · cited in 4 Illinois opinions naming this issue, 2013–2020
2 sentences

2020People v. Gaucho, 122 Ill. 2d 221, 248 (1988). ¶ 50 Here, Halloran’s testimony clearly fell within the course of investigation exception.

2014Jones, 153 Ill. 2d at 160 (substance of statement normally inadmissible under course-of-investigation exception); Morgan, 142 Ill. 2d at 447 (same); Gacho, 122 Ill. 2d at 248 (same). ¶ 35 In People v. Jura, 352 Ill.

44
People v. Morgangreen
ill · 1991 · cited in 3 Illinois opinions naming this issue, 2013–2014
2 sentences

2014Jones, 153 Ill. 2d at 160 (substance of statement normally inadmissible under course-of-investigation exception); Morgan, 142 Ill. 2d at 447 (same); Gacho, 122 Ill. 2d at 248 (same). ¶ 35 In People v. Jura, 352 Ill.

2014Jones, 153 Ill. 2d at 160 (substance of statement normally inadmissible under course-of-investigation exception); Morgan, 142 Ill. 2d at 447 (same); Gacho, 122 Ill. 2d at 248 (same). ¶ 35 In People v. Jura, 352 Ill.

33
People v. Juragreen
illappct · 2004 · cited in 3 Illinois opinions naming this issue, 2013–2014
2 sentences

2014Jones, 153 Ill. 2d at 160 (substance of statement normally inadmissible under course-of-investigation exception); Morgan, 142 Ill. 2d at 447 (same); Gacho, 122 Ill. 2d at 248 (same). ¶ 35 In People v. Jura, 352 Ill.

2014The Jura court noted that the substance of the message "directly impacts the very essence of the dispute: whether the defendant was the man who possessed the gun." Id. at 1088 .

33
People v. Jonesgreen
ill · 1992 · cited in 3 Illinois opinions naming this issue, 2013–2014
2 sentences

2014Jones, 153 Ill. 2d at 160 (substance of statement normally inadmissible under course-of-investigation exception); Morgan, 142 Ill. 2d at 447 (same); Gacho, 122 Ill. 2d at 248 (same). ¶ 35 In People v. Jura, 352 Ill.

2014Jones, 153 Ill. 2d at 160 (substance of statement normally inadmissible under course-of-investigation exception); Morgan, 142 Ill. 2d at 447 (same); Gacho, 122 Ill. 2d at 248 (same). ¶ 35 In People v. Jura, 352 Ill.

33
People v. Edgecombegreen
illappct · 2000 · cited in 3 Illinois opinions naming this issue, 2013–2014
2 sentences

2014People v. Edgecombe, 317 Ill.

2014People v. Edgecombe, 317 Ill.

33
People v. Rushgreen
illappct · 2010 · cited in 2 Illinois opinions naming this issue, 2021–2022
2 sentences

2022People v. Rush, 401 Ill.

2022People v. Rush, 401 Ill.

22
In re Jovan A.green
illappct · 2014 · cited in 2 Illinois opinions naming this issue, 2021–2022
2 sentences

2022In re Jovan A., 2014 IL App (1st) 103835 , ¶ 23.

2021See In re Jovan A., 2014 IL App (1st) 103835, ¶ 23 ; People v. Rush, 401 Ill.

12
People v. Harrisgreen
illappct · 2022 · cited in 1 Illinois opinions naming this issue, 2025–2025
1 sentence

2025See People v. Harris, 2022 IL App (1st) 192509, ¶ 61 .

11
People v. Andersongreen
illappct · 2017 · cited in 1 Illinois opinions naming this issue, 2019–2019
1 sentence

2019However, de novo review of evidentiary rulings applies when “a trial court’s exercise of discretion has been frustrated by an erroneous rule of law” (People v. Anderson, 2017 IL App (1st) 122640, ¶ 49 (internal quotation marks omitted)), and in this case, defendant does not claim the course of investigation rule was inapplicable to Chapton’s testimony.

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. Caffey green
ill · 2001
1 sentence

2026An abuse of discretion occurs “where the trial court’s ruling is arbitrary, fanciful, unreasonable, or where no reasonable person would take the view adopted by the trial court.” Id. at 89 . ¶ 78 On appeal, defendant contends that the trial court erred by allowing hearsay using the course of investigation exception for Deputy Fann’s testimony and also erred in allowing the excited utterance exception for Deputy Fann’s testimony at the pretrial hearing.

12026–2026
People v. Caraga green
illappct · 2018
1 sentence

2026People v. Caraga, 2018 IL App (1st) 170123, ¶ 36 .

12026–2026
Commonwealth Edison Company v. Illinois Commerce Commission green
ill · 2016
1 sentence

2026An appellate issue is moot when no actual controversy exists, or events occur that “make it impossible for the reviewing court to render effectual relief.” Commonwealth Edison Co. v. Illinois Commerce Comm’n, 2016 IL 118129 , ¶ 10.

12026–2026
People v. Wheeler green
illappct · 1989
2 sentences

2022Id. ¶ 51. ¶ 178 As in Temple, we find that defendant’s claims relating to the unobjected-to admission of (1) allegedly prior consistent statements by Mr. and Ms. Pavon and Ms. Shalabi; (2) irrelevant evidence; (3) improper leading questions; and (4) police testimony that allegedly exceeded the course-of-investigation exception are not properly regarded as structural error. ¶ 179 Our conclusion is not altered by People v. Wheeler, 186 Ill.

2022Id. ¶ 51. ¶ 178 As in Temple, we find that defendant’s claims relating to the unobjected-to admission of (1) allegedly prior consistent statements by Mr. and Ms. Pavon and Ms. Shalabi; (2) irrelevant evidence; (3) improper leading questions; and (4) police testimony that allegedly exceeded the course-of-investigation exception are not properly regarded as structural error. ¶ 179 Our conclusion is not altered by People v. Wheeler, 186 Ill.

12022–2022

Statutes the citing opinions construe

IL § 720 ILCS 5/16-1 (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.

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