Watson rule (Illinois) · Go Syfert
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Watson rule in Illinois

11 Illinois opinions name it 2 courts 1979–2025 2 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 (5)

CaseFollowedCited
People v. Whitmoregreen
illappct · 2023 · cited in 2 Illinois opinions naming this issue, 2024–2025
2 sentences

2025The State replied that recent caselaw from this court interpreted the Code as amended by the Pretrial Fairness Act as permitting the State to petition to detain within 21 days of receiving notice that a defendant wants to litigate any other issue under the new law. ¶7 The trial court overruled Watson’s objection, concluding one of those recent decisions was “controlling.” See People v. Whitmore, 2023 IL App (1st) 231807, ¶ 16 (holding State may petition to deny pretrial release after defendant moves for relief from financial conditions pretrial release).

2024The State replied that recent caselaw from this court interpreted the Code as amended by the Pretrial Fairness Act as permitting the State to petition to detain within 21 days of receiving notice that a defendant wants to litigate any other issue under the new law. ¶7 The trial court overruled Watson’s objection, concluding one of those recent decisions was “controlling.” See People v. Whitmore, 2023 IL App (1st) 231807, ¶ 16 (holding State may petition to deny pretrial release after defendant moves for relief from financial conditions pretrial release).

22
Outboard Marine Corp. v. Liberty Mutual Insurancegreen
ill · 1992 · cited in 1 Illinois opinions naming this issue, 2009–2009
1 sentence

2009An insurer’s duty to defend arises if the “facts alleged in the underlying complaint fall within, or potentially within, the policy’s coverage.” Outboard Marine Corp. v. Liberty Mutual Insurance Co., 154 III. 2d 90, 108, 607 N.E.2d 1204, 1212 (1992).

11
People Ex Rel. Douglas v. Woodsgreen
ill · 1968 · cited in 1 Illinois opinions naming this issue, 1994–1994
1 sentence

1994Douglas v. Woods (1968), 39 Ill. 2d 381, 384 (Watson rule held not to apply where proceeding not criminal and expert assistance sought was not on a crucial issue).

11
People v. Nicholsgreen
illappct · 1979 · cited in 1 Illinois opinions naming this issue, 1994–1994
1 sentence

1994App. 3d 726, 730 (considering Glover and Watson analysis as standard); People v. Nichols (1979), 70 Ill.

11
The PEOPLE v. Glovergreen
ill · 1971 · cited in 1 Illinois opinions naming this issue, 1979–1979
2 sentences

1979See People v. Glover (1971), 49 Ill. 2d 78 , 273 N.E.2d 367 ; People v. Vines (1976), 43 Ill.

1979See People v. Glover (1971), 49 Ill. 2d 78 , 273 N.E.2d 367 ; People v. Vines (1976), 43 Ill.

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
Pekin Insurance v. Wilson green
ill · 2010
2 sentences

2012They argued instead under the supreme court's ruling in Pekin Insurance Co. v. Wilson (Wilson II), 237 Ill.2d 446 , 341 Ill.Dec. 497 , 930 N.E.2d 1011 (2010), the trial court may consider not just the complaint but also other pleadings in determining whether the insurer has a duty to defend. ¶ 22 In May 2011, the trial court granted Danner and Watson's motion for summary judgment and denied Farmers' motion for summary judgment.

2012They argued instead under the supreme court's ruling in Pekin Insurance Co. v. Wilson (Wilson II), 237 Ill.2d 446 , 341 Ill.Dec. 497 , 930 N.E.2d 1011 (2010), the trial court may consider not just the complaint but also other pleadings in determining whether the insurer has a duty to defend. ¶ 22 In May 2011, the trial court granted Danner and Watson's motion for summary judgment and denied Farmers' motion for summary judgment.

22012–2012
People v. Broyld green
illappct · 1986
1 sentence

1989App. 3d 693 , 497 N.E.2d 147 , where the court agreed with the Watson requirement that the defendant must be admonished personally and in court about trial in absentia.

11989–1989
People v. Lester green
illappct · 1988
1 sentence

1989Since the case law is clear that the defendant must be orally warned in person, and courts have given strict construction to this statute (Lester (1988), 165 Ill.

11989–1989
Presbyterian Church in US v. Mary Elizabeth Blue Hull Memorial Presbyterian Church green
scotus · 1969
2 sentences

1984An alternative to the strict deference of Watson was identified in Presbyterian Church v. Mary Elizabeth Blue Hull Memorial Presbyterian Church (1969), 393 U.S. 440 , 21 L.

1984An alternative to the strict deference of Watson was identified in Presbyterian Church v. Mary Elizabeth Blue Hull Memorial Presbyterian Church (1969), 393 U.S. 440 , 21 L.

11984–1984
Watson v. Byerly Aviation, Inc. green
illappct · 1972
2 sentences

1984App. 3d 662, 670 , 288 N.E.2d 233, 239 .) The Watson rule is no different than the Sampson rule, because under either rule, the question is whether the bailee’s conduct was reasonable under the circumstances.

1984App. 3d 662, 670 , 288 N.E.2d 233, 239 .) The Watson rule is no different than the Sampson rule, because under either rule, the question is whether the bailee’s conduct was reasonable under the circumstances.

11984–1984
Watson v. Fischbach green
ill · 1973
2 sentences

1980A similar instruction, if requested by plaintiff, will be given at the close of the case as a part of the written instructions.” ( 54 Ill. 2d 498, 503 , 301 N.E.2d 303, 306 .) The plaintiffs contend the jurors will not understand “the legal and logical basis for permitting what to them may well seem a double recovery” and urge this court to reexamine the Watson rule.

1980A similar instruction, if requested by plaintiff, will be given at the close of the case as a part of the written instructions.” ( 54 Ill. 2d 498, 503 , 301 N.E.2d 303, 306 .) The plaintiffs contend the jurors will not understand “the legal and logical basis for permitting what to them may well seem a double recovery” and urge this court to reexamine the Watson rule.

11980–1980
People v. Vines green
illappct · 1976
2 sentences

1979See People v. Glover (1971), 49 Ill. 2d 78 , 273 N.E.2d 367 ; People v. Vines (1976), 43 Ill.

1979See People v. Glover (1971), 49 Ill. 2d 78 , 273 N.E.2d 367 ; People v. Vines (1976), 43 Ill.

11979–1979

Where else courts name it

CA 1201 (1964–2026) LA 28 (1982–2025) TX 25 (1994–2026) IA 15 (2001–2026) OH 12 (1983–2026) GA 12 (1970–2021) IL 11 (1979–2025) PA 9 (1960–2024) WA 8 (1988–2025) AZ 7 (1971–2017) MD 6 (1986–2021) AL 6 (1976–2016) SC 5 (1987–2016) MS 5 (1994–2026) MI 5 (1970–2022) ND 5 (1998–2022) NC 5 (1987–2008) TN 4 (2017–2025) MO 4 (2012–2020) DE 4 (2024–2025) FL 4 (1989–2021) AR 4 (2002–2020) IN 4 (1972–2019) VA 4 (1998–2022) NV 3 (2014–2019) NY 3 (1953–2017) CO 2 (1985–1998) NM 2 (1970–1971) WI 2 (2007–2022) DC 2 (2015–2022) MA 2 (1983–2002) MT 2 (2001–2002) VT 2 (2016–2018) ID 2 (1978–1995)

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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