single-subject rule (Illinois) · Go Syfert
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single-subject rule in Illinois

80 Illinois opinions name it 2 courts 1979–2025 9 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 (18)

CaseFollowedCited
People v. Reedygreen
ill · 1999 · cited in 22 Illinois opinions naming this issue, 1999–2025
2 sentences

2003The original truth-in-sentencing law, enacted in 1994, was held unconstitutional by the supreme court in People v. Reedy , 186 Ill. 2d 1, 11 (1999), which stated that the provisions were enacted as part of a statute that violated the single-subject requirement of the Illinois Constitution (Ill.

2003The original truth-in-sentencing law, enacted in 1994, was held unconstitutional by the supreme court in People v. Reedy, 186 Ill. 2d 1, 11 (1999), which stated that the provisions were enacted as part of a statute that violated the single-subject requirement of the Illinois Constitution (Ill.

822
People v. Cervantesgreen
ill · 1999 · cited in 15 Illinois opinions naming this issue, 2000–2023
2 sentences

2023Thus, when the supreme court in Cervantes struck down the public act as facially unconstitutional for violating the single-subject rule (Cervantes, 189 Ill. 2d at 98 ), the provision under which defendant was convicted remained unchanged.

2011Jan. 1, 1995)), which our supreme court found unconstitutional in People v. Cervantes, 189 Ill. 2d 80, 89 (1999), because it violated the single-subject rule.

515
Johnson v. Edgargreen
ill · 1997 · cited in 14 Illinois opinions naming this issue, 1997–2025
2 sentences

2025In Johnson v. Edgar, 176 Ill. 2d 499, 518, 523 (1997) our supreme court held that Public Act 89-428 violated the single-subject rule of the Illinois Constitution (Ill.

2024However, Public Act 89-428 was later held unconstitutional in Johnson v. Edgar, 176 Ill. 2d 499 (1997), as violating the single-subject clause.

514
People v. Carreragreen
ill · 2002 · cited in 5 Illinois opinions naming this issue, 2007–2016
2 sentences

2016Id. at 3, 8, 16 .

2016Id. at 14-15 . ¶ 25 Our supreme court thus refused to apply the good-faith exception to the defendant’s case, concluding that to do so “would run counter to our single-subject clause and void ab initio jurisprudence–specifically, that once a statute is declared facially unconstitutional, it is as if it had never been enacted.” Id. at 16 .

35
People v. Wootersgreen
ill · 1999 · cited in 5 Illinois opinions naming this issue, 2001–2021
2 sentences

2021Although it is true the supreme court found Public Acts 89-428 and 89-203 void as violative of the single-subject rule in Johnson v. Edgar, 176 Ill. 2d 499, 518 , 680 N.E.2d 1372, 1381 (1997), and People v. Wooters, 188 Ill. 2d 500 , 514, 722 N.E.2d 1102 , 1110 (1999), respectively, these findings have no relation to defendant’s conviction and sentence.

2021Although it is true the supreme court found Public Acts 89-428 and 89-203 void as violative of the single-subject rule in Johnson v. Edgar, 176 Ill. 2d 499, 518 , 680 N.E.2d 1372, 1381 (1997), and People v. Wooters, 188 Ill. 2d 500 , 514, 722 N.E.2d 1102 , 1110 (1999), respectively, these findings have no relation to defendant’s conviction and sentence.

25
People v. Burdunicegreen
ill · 2004 · cited in 4 Illinois opinions naming this issue, 2004–2005
2 sentences

2004If that purpose is permitted to be defined broadly, as it is under a single-subject analysis for instance (see People v. Burdunice, 211 Ill. 2d 264, 269 , 811 N.E.2d 678 (2004) (stating that “criminal law” qualifies as a legitimate single subject for a statute)), then all criminal statutes will qualify for cross-comparison analysis.

2004If that purpose is permitted to be defined broadly, as it is under a single-subject analysis for instance (see People v. Burdunice, 211 Ill. 2d 264, 269 , 811 N.E.2d 678 (2004) (stating that “criminal law” qualifies as a legitimate single subject for a statute)), then all criminal statutes will qualify for cross-comparison analysis.

24
Fuehrmeyer v. City of Chicagogreen
ill · 1974 · cited in 3 Illinois opinions naming this issue, 1987–1995
2 sentences

1995See Fuehrmeyer v. City of Chicago (1974), 57 Ill.2d 193 , 311 N.E.2d 116 (examination of journals, in violation of the enrolled-bill rule, not necessary because statute, on its face, clearly violated the single-subject requirement).

1995See Fuehrmeyer v. City of Chicago (1974), 57 Ill. 2d 193 (examination of journals, in violation of the enrolled-bill rule, not necessary because statute, on its face, clearly violated the single-subject requirement).

23
People v. Browngreen
ill · 2007 · cited in 2 Illinois opinions naming this issue, 2010–2010
2 sentences

2010People v. Brown, 225 Ill. 2d 188, 198 (2007).

2010People v. Brown, 225 Ill. 2d 188, 198 (2007).

22
People v. Morgangreen
ill · 2004 · cited in 2 Illinois opinions naming this issue, 2007–2007
2 sentences

2007Although successive postconviction petitions are generally not permitted (see 725 ILCS 5/122 — 3 (West 1998)), defendant argued that fundamental fairness called for relaxation of that rule in this case (see People v. Morgan, 212 Ill. 2d 148, 153 (2004)) because the Safe Neighborhoods Law, which added the rebuttable presumption provision under which he was transferred to criminal court, had since been declared unconstitutional and void ab initio by our court in People v. Cervantes, 189 Ill. 2d 80 (1999), on the grounds that it violated the single-subject clause of the Illinois Constitution of 1

2007Although successive postconviction petitions are generally not permitted (see 725 ILCS 5/122–3 (West 1998)), defendant argued that fundamental fairness called for relaxation of that rule in this case (see People v. Morgan, 212 Ill. 2d 148, 153 (2004)) because the Safe Neighborhoods Law, which added the rebuttable presumption provision under which he was transferred to criminal court, had since been declared unconstitutional and void ab initio by our court in People v. Cervantes, 189 Ill. 2d 80 (1999), on the grounds that it violated the single-subject clause of the Illinois Constitution of 197

22
People v. Terrygreen
illappct · 2002 · cited in 2 Illinois opinions naming this issue, 2005–2005
2 sentences

2005See People v. Terry , 329 Ill.

2005See People v. Terry, 329 Ill.

22
Arangold Corp. v. Zehndergreen
ill · 1999 · cited in 2 Illinois opinions naming this issue, 2005–2005
2 sentences

2005Arangold Corp. v. Zehnder, 187 Ill. 2d 341, 352 , 718 N.E.2d 191, 198 (1999) (Arangold I).

2005Arangold Corp. v. Zehnder, 187 Ill. 2d 341, 352 , 718 N.E.2d 191, 198 (1999) (Arangold I).

22
People v. Vilcesgreen
illappct · 2001 · cited in 2 Illinois opinions naming this issue, 2002–2002
2 sentences

2002People v. Vilces, 321 Ill.

2002People v. Vilces , 321 Ill.

22
Schlenz v. Castlegreen
ill · 1981 · cited in 2 Illinois opinions naming this issue, 1986–1987
2 sentences

1987Accord, Schlenz v. Castle (1981), 84 Ill. 2d 196 ; People ex rel.

1986See also Schlenz v. Castle (1981), 84 Ill. 2d 196, 209-11 (applying Carey to amendments to the Revenue Act of 1939).

22
People v. Reedygreen
illappct · 1998 · cited in 3 Illinois opinions naming this issue, 1999–2021
2 sentences

2021See People v. Reedy, 295 Ill.

1999Reedy, 295 Ill.

13
People v. Tellez-Valenciagreen
ill · 1999 · cited in 1 Illinois opinions naming this issue, 2023–2023
2 sentences

2023People v. Tellez-Valencia, 188 Ill. 2d 523, 525-26 , 723 N.E.2d 223, 224-25 (1999).

2023People v. Tellez-Valencia, 188 Ill. 2d 523, 525-26 , 723 N.E.2d 223, 224-25 (1999).

11
People v. Smithgreen
illappct · 2000 · cited in 1 Illinois opinions naming this issue, 2021–2021
1 sentence

2021See People v. Smith, 314 Ill.

11
People v. Jones Replaces opinion filed Oct. 26, 2000green
illappct · 2000 · cited in 1 Illinois opinions naming this issue, 2001–2001
1 sentence

2001See People v. Jones, 317 Ill.

11
People v. Majorsgreen
illappct · 1999 · cited in 1 Illinois opinions naming this issue, 2000–2000
1 sentence

2000See People v. Majors, 308 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 (20)

CaseCitedYears
People v. Holmes green
ill · 2017
2 sentences

2019As the State observes, however, as the supreme court later explained in People v. Holmes , 2017 IL 120407 , 418 Ill.Dec. 254 , 90 N.E.3d 412 , the Carrera majority specifically declined to consider whether the good-faith exception to the exclusionary ruled applied, because Carrera involved a statute enacted in violation of the single-subject clause of the Illinois Constitution ( Ill.

2019As the State observes, however, as the supreme court later explained in People v. Holmes , 2017 IL 120407 , 418 Ill.Dec. 254 , 90 N.E.3d 412 , the Carrera majority specifically declined to consider whether the good-faith exception to the exclusionary ruled applied, because Carrera involved a statute enacted in violation of the single-subject clause of the Illinois Constitution ( Ill.

22019–2019
People v. Foster green
illappct · 2000
2 sentences

2012We note this court found Public Act 89-688 was unconstitutional because it violated the single-subject rule, which means the matters included in Public Act 89-688 did not have a natural and logical connection to a single subject (see Foster, 316 Ill.

2012We note this court found Public Act 89-688 was unconstitutional because it violated the single-subject rule, which means the matters included in Public Act 89-688 did not have a natural and logical connection to a single subject (see Foster, 316 Ill.

22012–2012
Edwards v. Arizona green
scotus · 1981
2 sentences

2010Ed. 2d 378 , 101 S. Ct. 1880 (1981); (2) we must reverse the conviction because the State failed to prove the requisite mental state; and (3) even if we affirm the finding of guilt, we must vacate the sentence and remand the cause for a new sentencing hearing No. 2--08--0569 because defendant's life sentence violates the single-subject rule of the Illinois Constitution (Ill.

2010Ed. 2d 378 , 101 S. Ct. 1880 (1981); (2) we must reverse the conviction because the State failed to prove the requisite mental state; and (3) even if we affirm the finding of guilt, we must vacate the sentence and remand the cause for a new sentencing hearing because defendant’s life sentence violates the single-subject rule of the Illinois Constitution (Ill.

22010–2010
People v. Lahr green
ill · 1992
2 sentences

2008In holding that defendant's suppression motion had been properly granted, this court first looked to its prior decision in People v. Lahr, 147 Ill.2d 379 , 168 Ill.Dec. 139 , 589 N.E.2d 539 (1992), wherein the court suppressed evidence obtained during the course of an extraterritorial arrest.

2008In holding that defendant’s suppression motion had been properly granted, this court first looked to its prior decision in People v. Lahr, 147 Ill. 2d 379 (1992), wherein the court suppressed evidence obtained during the course of an extraterritorial arrest.

22008–2008
People v. Wiggins green
illappct · 1998
2 sentences

2007While the First District, from which this case arose, took the view that the statute did not offend the single-subject rule (see People v. Wiggins, 298 Ill.

2007While the First District, from which this case arose, took the view that the statute did not offend the single-subject rule (see People v. Wiggins, 298 Ill.

22007–2007
People v. Dunigan green
ill · 1995
2 sentences

2004Plaintiffs also challenge the constitutionality of the 1996 amendment on single-subject grounds. “[A] legislative enactment violates the single-subject requirement only when the statute, on its face, clearly embraces more than one subject.” People v. Dunigan, 165 Ill. 2d 235, 254-55 , 650 N.E.2d 1026 (1995).

2004Plaintiffs also challenge the constitutionality of the 1996 amendment on single-subject grounds. “[A] legislative enactment violates the single-subject requirement only when the statute, on its face, clearly embraces more than one subject.” People v. Dunigan, 165 Ill. 2d 235, 254-55 , 650 N.E.2d 1026 (1995).

22004–2004
Bernier v. Burris green
ill · 1986
2 sentences

2003Bernier v. Burris, 113 Ill. 2d 219 , 497 N.E.2d 763 (1986).

2003Bernier v. Burris, 113 Ill. 2d 219 , 497 N.E.2d 763 (1986).

22003–2003
People v. Ciesler green
illappct · 1999
2 sentences

2001Ciesler, 304 Ill.

2001Ciesler , 304 Ill.

22001–2001
People v. Hulitt green
illappct · 2005
1 sentence

2022It then concluded, without citation to Illinois law or any other source, with this: “Defendant could not raise it as an affirmative defense and, therefore, should not be permitted to raise it in the guise of a reasonable doubt argument.” Id. 1 For the sake of completeness, Public Act 89-404 was later invalidated in its entirety as violative of the single-subject rule.

12022–2022
Advincula v. United Blood Services green
ill · 1996
1 sentence

2021Johnson v. Edgar, 176 Ill. 2d 1 Defendant brought a motion to sever counts I and II, which the trial court granted.

12021–2021
Anderson v. Department of Mental Health & Developmental Disabilities neutral
illappct · 1999
1 sentence

2013Anderson, 305 Ill.

12013–2013
People v. Pitts green
illappct · 1998
1 sentence

1998App. 3d 182 , 691 N.E.2d 1174 (1998), which held that Public Act 89 — 404 was enacted in violation of the single-subject rule of the Illinois Constitution, have no bearing on this case.

11998–1998
Benjamin v. Devon Bank green
ill · 1977
11995–1995
People Ex Rel. Ogilvie v. Lewis green
ill · 1971
11995–1995
Geja's Cafe v. Metropolitan Pier & Exposition Authority green
ill · 1992
11995–1995
Stein v. Howlett green
ill · 1972
11995–1995
People Ex Rel. Gutknecht v. City of Chicago green
ill · 1953
11994–1994
SANGAMON CTY. FAIR AND AGRICULTURAL ASS'N v. Stanard green
ill · 1956
11986–1986
People v. Bullard green
ill · 1975
11985–1985
In Re Marriage of Thompson green
illappct · 1979
11979–1979

Statutes the citing opinions construe

IL § 730 ILCS 5/5-8-1 (11) IL § 720 ILCS 5/9-1 (9) IL § 725 ILCS 5/122-1 (7) IL § 730 ILCS 5/3-6-3 (6) IL § 735 ILCS 5/2-1401 (5) IL § 735 ILCS 5/2-615 (5) IL § 30 ILCS 105/1 (4) IL § 720 ILCS 5/12-4.2 (4) IL § 720 ILCS 5/8-4 (4) IL § 730 ILCS 150/1 (4) IL § 730 ILCS 150/2 (4) IL § 730 ILCS 150/3 (4)

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

FL 161 (1984–2024) IL 80 (1979–2025) PA 63 (2001–2024) CA 59 (1978–2024) CO 56 (1995–2022) WA 27 (2000–2019) OR 21 (1993–2024) OH 18 (1997–2023) OK 18 (1980–2021) TX 12 (2010–2015) IA 12 (1989–2023) NV 10 (2006–2024) MT 7 (1999–2025) AZ 6 (1987–2024) MN 4 (2000–2018) NE 4 (2022–2024) AK 4 (1979–2022) UT 3 (2013–2013) WY 2 (1994–1994) KS 2 (2012–2012) MD 2 (1990–2000) SD 2 (2021–2024) MO 2 (2009–2020) AL 2 (1991–2015)

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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