two prongs rule (Illinois) · Go Syfert
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two prongs rule in Illinois

11 Illinois opinions name it 2 courts 1998–2025 1 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 (4)

CaseFollowedCited
Terry v. Ohiogreen
scotus · 1968 · cited in 3 Illinois opinions naming this issue, 2017–2017
2 sentences

2017Terry v. Ohio, 392 U.S. 1, 19-20 (1968). 8 ¶ 33 I.

2017Terry v. Ohio, 392 U.S. 1, 19-20 (1968). 8 ¶ 33 I.

33
People v. Mullengreen
ill · 1990 · cited in 2 Illinois opinions naming this issue, 2006–2006
2 sentences

2006As this court noted in People v. Mullen, 141 Ill. 2d 394, 402 (1990), in cases “where the evidence is closely balanced, the probability that a defendant’s conviction was caused by even a minor trial error is greatly enhanced.

2006As this court noted in People v. Mullen, 141 Ill.2d 394, 402 , 152 Ill.Dec. 535 , 566 N.E.2d 222 (1990), in cases "where the evidence is closely balanced, the probability that a defendant's conviction was caused by even a minor trial error is greatly enhanced." Therefore, in those cases, the court will invoke the plain error rule so that it can determine whether an error, which was not objected to at trial and in post-trial motions, raises doubts as to the validity of the jury's verdict." Thus, the reviewing court concerns itself with the specific effect that an alleged error may have had on *

22
People v. Vargasgreen
ill · 1996 · cited in 2 Illinois opinions naming this issue, 1998–1998
2 sentences

1998See Vargas, 174 Ill.2d at 363 , 220 Ill.Dec. 616 , 673 N.E.2d 1037 .

1998See Vargas, 174 Ill. 2d at 363 .

22
People v. Frieberggreen
ill · 1992 · cited in 1 Illinois opinions naming this issue, 2025–2025
1 sentence

2025See People v. Frieberg, 147 Ill. 2d 326, 349 (1992) (“As used in its ordinary sense, the word ‘or’ marks an alternative indicating the various members of the sentence which it connects are to be taken separately.”).

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 (2)

CaseCitedYears
People v. Gonzalez green
ill · 2003
2 sentences

2008Gonzalez, 204 Ill. 2d at 228 .

2008Gonzalez, 204 Ill. 2d at 228 .

22008–2008
People v. Bunch green
ill · 2003
2 sentences

2003In effect, the majority blurs the distinction between the two prongs of the inquiry adopted in Gonzalez when it states that the officer "prolonged defendant's detention" (the duration factor) after "the purpose of the stop" (the scope factor) was completed. 207 *1034 Ill.2d at 17, 277 Ill.Dec. at 665 , 796 N.E.2d at 1031 .

2003In effect, the majority blurs the distinction between the two prongs of the inquiry adopted in Gonzalez when it states that the officer "prolonged defendant's detention" (the duration factor) after "the purpose of the stop" (the scope factor) was completed. 207 *1034 Ill.2d at 17, 277 Ill.Dec. at 665 , 796 N.E.2d at 1031 .

12003–2003

Statutes the citing opinions construe

IL § 625 ILCS 5/11-601 (3) IL § 720 ILCS 646/55 (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

NE 83 (1992–2026) CT 24 (1999–2025) AL 18 (1982–2024) WA 15 (1992–2025) TX 12 (1993–2020) IL 11 (1998–2025) NM 10 (1993–2025) OH 8 (1987–2021) IN 7 (2000–2013) MS 7 (1993–2024) MO 6 (1992–2020) MN 5 (2006–2025) OR 4 (1981–2011) MD 4 (1984–2006) CA 3 (1984–1992) SD 3 (1978–1979) NJ 3 (2000–2015) ID 3 (1995–2002) AK 2 (1985–2006) MA 2 (2018–2025) KY 2 (2022–2022)

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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