79 Illinois opinions name it 2 courts 1900–2025 11 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.
| Case | Followed | Cited |
|---|---|---|
People v. Janesgreen2 sentences2017App. 3d 957 (1990), granted the defendants therein “the right to file a new motion to withdraw guilty plea and the right to have a hearing on the new motion” (emphases added) (Janes, 158 Ill. 2d at 33 ) as a remedy for counsel’s failure to comply with the certificate requirement. 2017App. 3d 957 (1990), granted the defendants therein “the right to file a new motion to withdraw guilty plea and the right to have a hearing on the new motion” (emphases added) (Janes, 158 Ill. 2d at 33 ) as a remedy for counsel’s failure to comply with the certificate requirement. | 13 | 24 |
People v. Shirleygreen2 sentences2021The rule’s certificate requirement states: “The defendant’s attorney shall file with the trial court a certificate stating that the attorney has consulted with the defendant either by phone, mail, electronic means or in person to ascertain defendant’s contentions of error in the sentence and the entry of the plea of guilty, has examined the trial court file and both the report of proceedings of the plea of guilty and the report of proceedings in the sentencing hearing, and has made any amendments to the motion necessary for adequate presentation of any defects in those proceedings.” Id. ¶ 20 “ 2014If the motion to -5- withdraw the plea is denied, that decision can be considered on review.” Id. at 104 . ¶ 15 With regard to the rule’s certificate requirement, this court stated: “Requiring the defendant’s counsel to file the requisite certificate enables the trial court to insure that counsel has reviewed the defendant’s claim and considered all relevant bases for the motion to withdraw the guilty plea or to reconsider the sentence.” (Emphasis added.) People v. Shirley, 181 Ill. 2d 359, 361 (1998). ¶ 16 In sum, a main purpose of Rule 604(d) is to ensure that any improper conduct or other a | 7 | 12 |
People v. Lindsaygreen2 sentences2020People v. Janes, 158 Ill. 2d 27 , 35- 36, 630 N.E.2d 790, 793-94 (1994); see also People v. Lindsay, 239 Ill. 2d 522, 531 , 942 N.E.2d 1268, 1273-74 . 2020People v. Janes, 158 Ill. 2d 27 , 35- 36, 630 N.E.2d 790, 793-94 (1994); see also People v. Lindsay, 239 Ill. 2d 522, 531 , 942 N.E.2d 1268, 1273-74 . | 3 | 3 |
Chicago Sheraton Corp. v. Zabangreen2 sentences2014App. 3d 103, 105 (2008); see Chicago Sheraton Corp. v. Zaban, 71 Ill. 2d 85, 91 (1978) (legislature intended the certificate of error procedure to be an expeditious summary process without the participation by the taxpayer for correcting the assessor's errors). 2014App. 3d 103, 105 (2008); see Chicago Sheraton Corp. v. Zaban, 71 Ill. 2d 85, 91 (1978) (legislature intended the certificate of error procedure to be an expeditious summary process without the participation by the taxpayer for correcting the assessor’s errors). | 2 | 7 |
Ball v. County of Cookgreen2 sentences2014Ball v. County of Cook, 385 Ill. 2014Ball v. County of Cook, 385 Ill. | 2 | 5 |
People v. Dickersongreen2 sentences2004Further, " '[a]dherence to a rule of strict compliance with the certificate requirement will not place an onerous burden on defense counsel, and, significantly, it will eliminate unnecessary appeals.' " Janes , 158 Ill. 2d at 35 , quoting People v. Dickerson , 212 Ill. 2004Further, “ ‘[ajdherence to a rule of strict compliance with the certificate requirement will not place an onerous burden on defense counsel, and, significantly, it will eliminate unnecessary appeals.’ ” Janes, 158 Ill. 2d at 35 , quoting People v. Dickerson, 212 Ill. | 2 | 5 |
People v. Johnsongreen2 sentences2023See People v. Johnson, 154 Ill. 2d 227, 241 (1993). 1999Counsel’s failure to file an affidavit certifying compliance with Rule 651(c) is harmless error if “the record demonstrates that counsel adequately fulfilled his duties as post-conviction counsel.” People v. Johnson, 154 Ill. 2d 227, 238 (1993), citing People v. Szabo, 144 Ill. 2d 525 (1991). | 2 | 3 |
People v. Martellgreen2 sentences2017See People v. Martell, 2015 IL App (2d) 141202 , ¶ 21 (citing People v. Lindsay, 239 Ill. 2d 522, 531 (2011)). 2017See People v. Martell, 2015 IL App (2d) 141202 , ¶ 21 (citing People v. Lindsay, 239 Ill. 2d 522, 531 (2011)). | 2 | 2 |
People v. Mastgreen2 sentences2000People v. Janes, 158 Ill. 2d 27, 35 (1994); People v. Mast, 305 Ill. 2000People v. Janes , 158 Ill. 2d 27, 35 (1994); People v. Mast , 305 Ill. | 2 | 2 |
Melendez-Diaz v. Massachusettsgreen2 sentences2013See id. at 329 . ¶ 52 Two other aspects of Melendez-Diaz are particularly notable for the purpose of this appeal. 2011Melendez-Diaz, 557 U.S. ___ , 129 S.Ct. at 2532 . | 1 | 2 |
Crawford v. Washingtongreen1 sentence2025See id. at 329 (citing Crawford, 541 U.S. 36 ). | 1 | 1 |
United Methodist Village Retirement Communities, Inc. v. Property Tax Appeal Boardgreen1 sentence2023According to a September 2004 letter from the Champaign County chief assessment officer to plaintiff, “although [s]uch a partial exemption may have been allowed in the past, *** it appears that partial exemptions are to be determined solely by the [Department].” See, e.g., United Methodist Village Retirement Communities, Inc., 321 Ill. | 1 | 1 |
Clemmons v. Travelers Insurance Co.green1 sentence2023Id. (quoting Clemmons v. Travelers Insurance Co., 88 Ill. 2d 469, 480-81 (1981)). ¶ 29 In determining whether substitute service was proper, we must consider the record as a whole. | 1 | 1 |
People v. Jenningsgreen1 sentence2023Counsel may either file a Rule 651(c) certificate or “the record as a whole may demonstrate that postconviction counsel complied with those requirements.” People v. Jennings, 345 Ill. | 1 | 1 |
| People v. Munetsigreen | 1 | 1 |
| People v. Heinzgreen | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Illinois. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
People v. Tousignant
green
2 sentences2021The rule’s certificate requirement states: “The defendant’s attorney shall file with the trial court a certificate stating that the attorney has consulted with the defendant either by phone, mail, electronic means or in person to ascertain defendant’s contentions of error in the sentence and the entry of the plea of guilty, has examined the trial court file and both the report of proceedings of the plea of guilty and the report of proceedings in the sentencing hearing, and has made any amendments to the motion necessary for adequate presentation of any defects in those proceedings.” Id. ¶ 20 “ 2021The rule’s certificate requirement enables the trial court “ ‘to ensure that counsel has reviewed the defendant’s claim and considered all relevant bases for the motion to withdraw the guilty plea or to reconsider the sentence.’ ” Id. (quoting People v. Tousignant, 2014 IL 115329, ¶ 16 ). | 8 | 2015–2021 |
People v. Wilk
green
2 sentences2014If the motion to -5- withdraw the plea is denied, that decision can be considered on review.” Id. at 104 . ¶ 15 With regard to the rule’s certificate requirement, this court stated: “Requiring the defendant’s counsel to file the requisite certificate enables the trial court to insure that counsel has reviewed the defendant’s claim and considered all relevant bases for the motion to withdraw the guilty plea or to reconsider the sentence.” (Emphasis added.) People v. Shirley, 181 Ill. 2d 359, 361 (1998). ¶ 16 In sum, a main purpose of Rule 604(d) is to ensure that any improper conduct or other a 2014If the motion to -5- withdraw the plea is denied, that decision can be considered on review.” Id. at 104 . ¶ 15 With regard to the rule’s certificate requirement, this court stated: “Requiring the defendant’s counsel to file the requisite certificate enables the trial court to insure that counsel has reviewed the defendant’s claim and considered all relevant bases for the motion to withdraw the guilty plea or to reconsider the sentence.” (Emphasis added.) People v. Shirley, 181 Ill. 2d 359, 361 (1998). ¶ 16 In sum, a main purpose of Rule 604(d) is to ensure that any improper conduct or other a | 6 | 1991–2014 |
People v. Easton
green
2 sentences2021The rule’s certificate requirement enables the trial court “ ‘to ensure that counsel has reviewed the defendant’s claim and considered all relevant bases for the motion to withdraw the guilty plea or to reconsider the sentence.’ ” Id. (quoting People v. Tousignant, 2014 IL 115329, ¶ 16 ). 2020The court further stated that “[i]f the certificate fails to meet this standard, a reviewing court must remand the case to the trial court for proceedings that strictly comply with Rule 604(d).” Id. ¶ 16 The certificate requirement in Rule 604(d) enables the trial court to ensure that counsel has reviewed a defendant’s claims and considered all of the relevant bases for a motion to withdraw the guilty plea or reconsider the sentence. | 3 | 2020–2021 |
Sears Holdings Corp. v. Pappas
green
2 sentences2011Id. at 148 . 2011Id. | 3 | 2009–2011 |
People v. Priest
green
2 sentences2019Because defendant’s attorney could not consult with defendant, she obviously could not certify that she had done so. ¶ 15 Although not precisely on point, People v. Priest, 345 Ill. 2019Because defendant's attorney could not consult with defendant, she obviously could not certify that she had done so. ¶ 15 Although not precisely on point, People v. Priest , 345 Ill. | 2 | 2019–2019 |
Sarkissian v. Chicago Board of Education
green
2 sentences2019But the certificate requirement is contained in the garnishment statute—specifically, in section 12-705 of the Code—and section 12-705 is not a statute “governing the service of process.” Id. 2018But the certificate requirement is contained in the garnishment statute-specifically, in section 12-705 of the Code-and section 12-705 is not a statute "governing the service of process." Id. | 2 | 2018–2019 |
Sorce v. Armstrong
green
2 sentences2011Id. at 1098-99 , 341 Ill.Dec. 77 , 929 N.E.2d 1156 . 2011Id. at 1098-99 , 341 Ill.Dec. 77 , 929 N.E.2d 1156 . | 2 | 2011–2011 |
Bullcoming v. New Mexico
green
2 sentences2011Bullcoming, 564 U.S. at ___ , 131 S. Ct. at 2710 . ¶ 76 The BAC report at issue in Bullcoming and the certificate of analysis at issue in Melendez-Diaz differ from the medical examiner’s report at issue in the instant case. 2011Bullcoming, 564 U.S. at ___ , 131 S.Ct. at 2710 . ¶ 76 The BAC report at issue in Bullcoming and the certificate of analysis at issue in Melendez-Diaz differ from the medical examiner's report at issue in the instant case. | 2 | 2011–2011 |
Subway Restaurants, Inc. v. Riggs
green
2 sentences2011Subway Restaurants, Inc., 297 Ill. 2011Subway Restaurants, Inc., 297 Ill. | 2 | 2011–2011 |
People ex rel. Rosewell v. 1040 Hollywood Building Partnership
green
2 sentences2008In re Application of the Cook County Treasurer for the 1968, 1973, 1980 & Other Tax Years, 172 Ill. 2008In re Application of the Cook County Treasurer for the 1968, 1973, 1980 & Other Tax Years, 172 Ill. | 2 | 2008–2008 |
People v. McCaskill
green
2 sentences2006Cf. People v. McCaskill, 298 Ill. 2006Cf. People v. McCaskill, 298 Ill. | 2 | 2006–2006 |
People v. Hampton
neutral
2 sentences2006“The certificate requirement allows ‘the trial court to insure that counsel has reviewed the defendant’s claim and considered all relevant bases for the motion to withdraw the guilty plea or to reconsider the sentence.’ ” People v. Hampton, 335 Ill. 2006“Our supreme court has held the certificate requirement of Rule 604(d) must be strictly complied with.” Hampton, 335 Ill. | 2 | 2006–2006 |
People v. Starks
green
2 sentences2005Even the Fourth District acknowledges that the trial courts can help to ensure that defense attorneys comply with the certificate requirement, and that "it is also in the interest of the State to ensure that strict compliance is observed as the State also has an interest in avoiding a failure to comply with Rule 604(d)." Starks , 344 Ill. 2005Even the Fourth District acknowledges that the trial courts can help to ensure that defense attorneys comply with the certificate requirement, and that “it is also in the interest of the State to ensure that strict compliance is observed as the State also has an interest in avoiding a failure to comply with Rule 604(d).” Starks, 344 Ill. | 2 | 2005–2005 |
People v. Szabo
green
2 sentences1999Counsel's failure to file an affidavit certifying compliance with Rule 651(c) is harmless error if "the record demonstrates that counsel adequately fulfilled his duties as post-conviction counsel." People v. Johnson, 154 Ill.2d 227, 238 , 182 Ill.Dec. 1 , 609 N.E.2d 304 (1993), citing People v. Szabo, 144 Ill.2d 525 , 163 Ill.Dec. 907 , 582 N.E.2d 173 (1991). 1999Counsel’s failure to file an affidavit certifying compliance with Rule 651(c) is harmless error if “the record demonstrates that counsel adequately fulfilled his duties as post-conviction counsel.” People v. Johnson, 154 Ill. 2d 227, 238 (1993), citing People v. Szabo, 144 Ill. 2d 525 (1991). | 2 | 1999–1999 |
People v. Norris
green
2 sentences1991App. 3d 536 , 361 N.E.2d 105 , this court held that the certificate requirement is applicable in all cases; however, substantial compliance with the rule in some cases is acceptable. 1977App. 3d 536 , 361 N.E.2d 105 , that substantial compliance with the certificate requirement is acceptable in some cases. | 2 | 1977–1991 |
| People v. Williams green | 1 | 2023–2023 |
State Bank of Lake Zurich v. Thill
green
1 sentence2023Id. (quoting Clemmons v. Travelers Insurance Co., 88 Ill. 2d 469, 480-81 (1981)). ¶ 29 In determining whether substitute service was proper, we must consider the record as a whole. | 1 | 2023–2023 |
| People v. Alarcon-Trujillo green | 1 | 2021–2021 |
| Panchinsin v. Enterprise Companies green | 1 | 2019–2019 |
| People v. Fricks green | 1 | 2017–2017 |
| People v. McPherson green | 1 | 2017–2017 |
| People v. Bailey green | 1 | 2015–2015 |
| People v. Dismuke green | 1 | 2006–2006 |
| People v. Johnson green | 1 | 1999–1999 |
| Fromm v. Rosewell green | 1 | 1988–1988 |
| Cook County Collector v. House neutral | 1 | 1988–1988 |
| In re Cook County Treasurer neutral | 1 | 1988–1988 |
| People v. Isringhaus green | 1 | 1986–1986 |
| People v. Brown green | 1 | 1986–1986 |
| Van Driel Drug Store, Inc. v. Mahin green | 1 | 1982–1982 |
| Clarendon Associates v. Korzen green | 1 | 1978–1978 |
| Acorn Auto Driving School, Inc. v. Board of Education of Leyden High School District No. 212 green | 1 | 1978–1978 |
| Dietman v. Hunter green | 1 | 1978–1978 |
| People v. Harris green | 1 | 1977–1977 |
| People v. Samuels green | 1 | 1977–1977 |
| Lawrence v. Traner green | 1 | 1900–1900 |
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.
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.