common-design rule in Illinois

77 Illinois opinions name it 2 courts 1969–2025 22 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 (33)

Case	Followed	Cited
In Re WCgreen ill · 1995 · cited in 34 Illinois opinions naming this issue, 1996–2025 2 sentences 2025“Under the common-design rule, if ‘two or more persons engage in a common criminal design or agreement, any acts in the furtherance of that common design committed by one party are considered to be the acts of all parties to the design or agreement and all are equally responsible for the consequences of the further acts.’ ” Id. (quoting In re W.C., 167 Ill. 2d 307, 337 (1995)). 28 ¶ 81 Defendant argues that no rational trier of fact could find him accountable beyond a reasonable doubt for the offenses at issue, where the only evidence that defendant shared a common purpose with Richardson came 2025“The common-design rule provides that where two or more persons engage in a common design or agreement, any acts in the furtherance of that common design committed by one party are considered to be the acts of all parties to the design or agreement and all are equally responsible for the consequences of the further acts.” In re W.C., 167 Ill. 2d 307, 337 (1995).	18	34
People v. Fernandezgreen ill · 2014 · cited in 35 Illinois opinions naming this issue, 2014–2025 2 sentences 2025“Under the common-design rule, if ‘two or more persons engage in a common criminal design or agreement, any acts in the furtherance of that common design committed by one party are considered to be the acts of all parties to the design or agreement and all are equally responsible for the consequences of the further acts.’ ” Id. (quoting In re W.C., 167 Ill. 2d 307, 337 (1995)). 28 ¶ 81 Defendant argues that no rational trier of fact could find him accountable beyond a reasonable doubt for the offenses at issue, where the only evidence that defendant shared a common purpose with Richardson came 2024“A person intends, or acts intentionally or with intent, to accomplish a result or engage in conduct described by the statute defining the offense, when his conscious objective or purpose is to accomplish that result or engage in that conduct.” 720 ILCS 5/4-4 (West 2014). ¶ 33 “Under the common-design rule, if two or more persons engage in a common criminal design or agreement, any acts in furtherance of that common design committed by one party are considered to be the acts of all parties to the design or agreement and all are equally responsible for the consequences of the further acts.” (In	11	35
People v. Terrygreen ill · 1984 · cited in 14 Illinois opinions naming this issue, 1988–2018 2 sentences 2018People v. Terry, 99 Ill. 2d 508, 515 (1984); People v. Kessler, 57 Ill. 2d 493, 496-97 (1974). ¶ 40 Under the common-design rule, if “two or more persons engage in a common criminal design or agreement, any acts in the furtherance thereof committed by one party are considered to be the acts of all parties to the common design and all are equally responsible for the consequences of such further acts.” Kessler, 57 Ill. 2d at 496-97 . 1995(See People v. Stanceil (1992), 153 Ill. 2d 218, 234-35 (citing People v. Terry (1984), 99 Ill. 2d 508 , and People v. Allen (1974), 56 Ill. 2d 536 ).) The common-design rule provides that where two or more persons engage in a common criminal design or agreement, any acts in the furtherance of that common design committed by one party are considered to be the acts of all parties to the design or agreement and all are equally responsible for the consequences of the further acts.	5	14
People v. Perezgreen ill · 2000 · cited in 8 Illinois opinions naming this issue, 2014–2024 2 sentences 2024Id. ¶ 41 Further, under the common-design rule, where two or more people engage in a common criminal design or agreement, any acts in furtherance committed by one party are considered the 14 No. 1-21-1545 acts of all parties, and all are equally responsible for those further acts. 2024Id. ¶ 41 Further, under the common-design rule, where two or more people engage in a common criminal design or agreement, any acts in furtherance committed by one party are considered the 14 No. 1-21-1545 acts of all parties, and all are equally responsible for those further acts.	4	8
People v. Coopergreen ill · 2000 · cited in 5 Illinois opinions naming this issue, 2014–2021 2 sentences 2021Accountability under the common-design rule “need not be supported by words of agreement” and “may be drawn from the circumstances surrounding the commission of the unlawful conduct.” Cooper, 194 Ill. 2d at 435 . ¶ 29 The evidence at trial overwhelmingly established defendant’s guilt of burglary. 2018Here, the common-design element is relevant. ¶ 54 Under the common-design rule, if “two or more persons engage in a common criminal design or agreement, any acts in the furtherance of that common design committed by one party are considered to be the acts of all parties to the design or agreement and all are equally responsible for the consequences of the further acts.” People v. Cooper, 194 Ill. 2d 419, 434-35 (2000).	4	5
People v. Phillipsgreen illappct · 2014 · cited in 10 Illinois opinions naming this issue, 2014–2024 2 sentences 2024“Evidence that a defendant voluntarily attached himself to a group bent on illegal acts with knowledge of its design supports an inference that he shared the common purpose *.” In re W.C., 167 Ill. 2d 307, 338 (1995). “[S]hared intent is not an element of the common-design rule.” (Emphasis in original.) People v. Phillips, 2014 IL App (4th) 120695, ¶ 48 . 2024**This evidence, under the common-design rule, would permit the State to “prove the accused had the specific intent to promote or facilitate a crime.” People v. Phillips, 2014 IL App (4th) 120695, ¶ 43 (quoting People v. Houston, 258 Ill.	3	10
People v. Rogersgreen illappct · 1992 · cited in 3 Illinois opinions naming this issue, 2014–2021 2 sentences 2021App. 3d 740, 752-53 , 636 N.E.2d 565, 574 (1992) (Greiman, P.J., specially concurring)). ¶ 69 As shown by the arguments in this case, our hopes have been dashed that the shared-intent requirement of the common-design rule has been killed. 2020App. 3d 740, 752-53 , 636 N.E.2d 565, 574 (1992) (Greiman, P.J., specially concurring)). ¶ 69 As shown by the arguments in this case, our hopes have been dashed that the shared- intent requirement of the common-design rule has been killed.	3	3
People v. Batchelorgreen ill · 1996 · cited in 3 Illinois opinions naming this issue, 2016–2020 2 sentences 2020A factfinder “may infer accountability from ‘the circumstances surrounding the perpetration of the unlawful conduct,’ including ‘the defendant’s presence during the commission of the offense, the defendant’s continued close affiliation with other offenders after the commission of the crime, the defendant’s failure to report the incident, and the defendant’s flight from the scene.’ ” People v. Doolan, 2016 IL App (1st) 141780, ¶ 43 (quoting People v. Batchelor, 171 Ill. 2d 367, 376 (1996)). ¶ 20 Here, the evidence viewed in a light most favorable to the State sufficed to establish that defendan 2017Rather, the trier of fact may infer accountability from “the circumstances surrounding the perpetration of the unlawful conduct,” including “the defendant’s presence during the commission of the offense, the defendant’s continued close affiliation with other offenders after the commission of the crime, the defendant’s failure to report the incident, and the defendant’s flight from the scene.” People v. Batchelor, 171 Ill. 2d 367, 376 (1996).	3	3
Brennan v. Peoplegreen ill · 1854 · cited in 6 Illinois opinions naming this issue, 1984–2014 2 sentences 2008The first decision from this court to discuss the common-design rule was Brennan v. People, 15 Ill. 511 (1854). 2008The first decision from this court to discuss the common-design rule was Brennan v. People, 15 Ill. 511 (1854).	2	6
People v. Jonesgreen ill · 1993 · cited in 4 Illinois opinions naming this issue, 2005–2023 2 sentences 2023In other words, “ ‘[c]ommon design refers to a criminal scheme of which the crime charged is only a part.’ ” People v. Jones, 156 Ill. 2d 225, 239 (1993). 2023In other words, “ ‘[c]ommon design refers to a criminal scheme of which the crime charged is only a part.’ ” People v. Jones, 156 Ill. 2d 225, 239 (1993).	2	4
The People v. Colegreen ill · 1964 · cited in 4 Illinois opinions naming this issue, 2014–2018 2 sentences 2018See also People v. Fernandez, 2014 IL 115527, ¶ 13 ; In re W.C., 167 Ill. 2d 307, 337 (1995); People v. J.H., 136 Ill. 2d 1 , 17 -8- (1990); Terry, 99 Ill. 2d at 514 ; People v. Cole, 30 Ill. 2d 375 (1964); People v. Marx, 291 Ill. 40, 48 (1919); Hamilton v. People, 113 Ill. 34 (1885). 2017See also People v. Fernandez , 2014 IL 115527 , ¶ 13, 379 Ill.Dec. 68 , 6 N.E.3d 145 ; In re W.C. , 167 Ill. 2d 307 , 337, 212 Ill.Dec. 563 , 657 N.E.2d 908 (1995) ; People v. J.H. , 136 Ill. 2d 1 , 17, 143 Ill.Dec. 889 , 554 N.E.2d 961 (1990) ; Terry , 99 Ill. 2d at 514 , 77 Ill.Dec. 442 , 460 N.E.2d 746 ; People v. Cole , 30 Ill. 2d 375 , 196 N.E.2d 691 (1964) ; People v. Marx , 291 Ill. 40 , 48, 125 N.E. 719 (1919) ; Hamilton v. People , 113 Ill. 34 (1885).	2	4
The People v. Rybkagreen ill · 1959 · cited in 3 Illinois opinions naming this issue, 1975–2014 2 sentences 2014See, e.g., People v. Rudecki, 309 Ill. 125, 129 , 140 N.E. 832, 833 (1923); Tarver, 381 Ill. at 416 , 45 N.E.2d at 632 ; People v. Rybka, 16 Ill. 2d 394, 405 , 158 N.E.2d 17, 22 (1959); People v. Torres, 19 Ill. 2d 497, 499 , 167 N.E.2d 412, 413 (1960); People v. Washington, 26 Ill. 2d 207, 209 , 186 N.E.2d 259, 261 (1962); People v. Cole, 30 Ill. 2d 375, 379 , 196 N.E.2d 691, 694 (1964); People v. Armstrong, 41 Ill. 2d 390, 399 , 243 N.E.2d 825, 830 (1968); People v. Hubbard, 55 Ill. 2d 142, 147-48 , 302 N.E.2d 609, 612 (1973); Kessler, 57 Ill. 2d at 497 , 315 N.E.2d at 32 ; People v. Terry, 2014See, e.g., People v. Rudecki, 309 Ill. 125, 129 , 140 N.E. 832, 833 (1923); Tarver, 381 Ill. at 416 , 45 N.E.2d at 632 ; People v. Rybka, 16 Ill. 2d 394, 405 , 158 N.E.2d 17, 22 (1959); People v. Torres, 19 Ill. 2d 497, 499 , 167 N.E.2d 412, 413 (1960); People v. Washington, 26 Ill. 2d 207, 209 , 186 N.E.2d 259, 261 (1962); People v. Cole, 30 Ill. 2d 375, 379 , 196 N.E.2d 691, 694 (1964); People v. Armstrong, 41 Ill. 2d 390, 399 , 243 N.E.2d 825, 830 (1968); People v. Hubbard, 55 Ill. 2d 142, 147-48 , 302 N.E.2d 609, 612 (1973); Kessler, 57 Ill. 2d at 497 , 315 N.E.2d at 32 ; People v. Terry,	2	3
People v. Malcolmgreen illappct · 2015 · cited in 2 Illinois opinions naming this issue, 2020–2021 2 sentences 2021EPILOGUE ¶ 68 Although the Illinois Appellate Court has followed the supreme court’s guidance on legal accountability since the Fernandez decision (see, e.g., People v. Williams, 2016 IL App (1st) 133459, ¶¶ 45-48 , 64 N.E.3d 1086 ; People v. James, 2017 IL App (1st) 143391, ¶¶ 56-57 , 93 N.E.3d 626 ; People v. Cowart, 2017 IL App (1st) 113085-B , ¶¶ 38-40, 81 N.E.3d 1023 ; Ealy, 2019 IL App (1st) 161575, ¶¶ 31-33 ; People v. Malcolm, 2015 IL App (1st) 133406, ¶¶ 40, 43 , 39 N.E.3d 98 ), defendants continue to raise “the bogus shared-intent requirement of the common-design rule” (Phillips, 201 2021EPILOGUE ¶ 68 Although the Illinois Appellate Court has followed the supreme court’s guidance on legal accountability since the Fernandez decision (see, e.g., People v. Williams, 2016 IL App (1st) 133459, ¶¶ 45-48 , 64 N.E.3d 1086 ; People v. James, 2017 IL App (1st) 143391, ¶¶ 56-57 , 93 N.E.3d 626 ; People v. Cowart, 2017 IL App (1st) 113085-B , ¶¶ 38-40, 81 N.E.3d 1023 ; Ealy, 2019 IL App (1st) 161575, ¶¶ 31-33 ; People v. Malcolm, 2015 IL App (1st) 133406, ¶¶ 40, 43 , 39 N.E.3d 98 ), defendants continue to raise “the bogus shared-intent requirement of the common-design rule” (Phillips, 201	2	2
People v. Dennisgreen ill · 1998 · cited in 2 Illinois opinions naming this issue, 2014–2014 2 sentences 2014Just as the felony-murder doctrine "seeks to deter persons from committing forcible felonies by holding them responsible for murder if a death results," the common-design rule "seeks to deter persons from intentionally aiding or encouraging the commission of offenses." People v. Dennis, 181 Ill. 2d 87, 105 , 692 N.E.2d 325, 335 (1998). ¶ 46 Defendant's argument that the State was required to prove that he shared Grimes's intent to fire the rifle illustrates the erroneous conflation of two distinct bases for proving legal accountability: (1) shared intent (sometimes referred to as "specific int 2014Just as the felony-murder doctrine "seeks to deter persons from committing forcible felonies by holding them responsible for murder if a death results," the common-design rule "seeks to deter persons from intentionally aiding or encouraging the commission of offenses." People v. Dennis, 181 Ill. 2d 87, 105 , 692 N.E.2d 325, 335 (1998). ¶ 46 Defendant's argument that the State was required to prove that he shared Grimes's intent to fire the rifle illustrates the erroneous conflation of two distinct bases for proving legal accountability: (1) shared intent (sometimes referred to as "specific int	2	2
The PEOPLE v. Washingtongreen ill · 1962 · cited in 2 Illinois opinions naming this issue, 2014–2014 2 sentences 2014See, e.g., People v. Rudecki, 309 Ill. 125, 129 , 140 N.E. 832, 833 (1923); Tarver, 381 Ill. at 416 , 45 N.E.2d at 632 ; People v. Rybka, 16 Ill. 2d 394, 405 , 158 N.E.2d 17, 22 (1959); People v. Torres, 19 Ill. 2d 497, 499 , 167 N.E.2d 412, 413 (1960); People v. Washington, 26 Ill. 2d 207, 209 , 186 N.E.2d 259, 261 (1962); People v. Cole, 30 Ill. 2d 375, 379 , 196 N.E.2d 691, 694 (1964); People v. Armstrong, 41 Ill. 2d 390, 399 , 243 N.E.2d 825, 830 (1968); People v. Hubbard, 55 Ill. 2d 142, 147-48 , 302 N.E.2d 609, 612 (1973); Kessler, 57 Ill. 2d at 497 , 315 N.E.2d at 32 ; People v. Terry, 2014See, e.g., People v. Rudecki, 309 Ill. 125, 129 , 140 N.E. 832, 833 (1923); Tarver, 381 Ill. at 416 , 45 N.E.2d at 632 ; People v. Rybka, 16 Ill. 2d 394, 405 , 158 N.E.2d 17, 22 (1959); People v. Torres, 19 Ill. 2d 497, 499 , 167 N.E.2d 412, 413 (1960); People v. Washington, 26 Ill. 2d 207, 209 , 186 N.E.2d 259, 261 (1962); People v. Cole, 30 Ill. 2d 375, 379 , 196 N.E.2d 691, 694 (1964); People v. Armstrong, 41 Ill. 2d 390, 399 , 243 N.E.2d 825, 830 (1968); People v. Hubbard, 55 Ill. 2d 142, 147-48 , 302 N.E.2d 609, 612 (1973); Kessler, 57 Ill. 2d at 497 , 315 N.E.2d at 32 ; People v. Terry,	2	2
The PEOPLE v. Armstrong (Sumlin)green ill · 1969 · cited in 2 Illinois opinions naming this issue, 2014–2014 2 sentences 2014See, e.g., People v. Rudecki, 309 Ill. 125, 129 , 140 N.E. 832, 833 (1923); Tarver, 381 Ill. at 416 , 45 N.E.2d at 632 ; People v. Rybka, 16 Ill. 2d 394, 405 , 158 N.E.2d 17, 22 (1959); People v. Torres, 19 Ill. 2d 497, 499 , 167 N.E.2d 412, 413 (1960); People v. Washington, 26 Ill. 2d 207, 209 , 186 N.E.2d 259, 261 (1962); People v. Cole, 30 Ill. 2d 375, 379 , 196 N.E.2d 691, 694 (1964); People v. Armstrong, 41 Ill. 2d 390, 399 , 243 N.E.2d 825, 830 (1968); People v. Hubbard, 55 Ill. 2d 142, 147-48 , 302 N.E.2d 609, 612 (1973); Kessler, 57 Ill. 2d at 497 , 315 N.E.2d at 32 ; People v. Terry, 2014See, e.g., People v. Rudecki, 309 Ill. 125, 129 , 140 N.E. 832, 833 (1923); Tarver, 381 Ill. at 416 , 45 N.E.2d at 632 ; People v. Rybka, 16 Ill. 2d 394, 405 , 158 N.E.2d 17, 22 (1959); People v. Torres, 19 Ill. 2d 497, 499 , 167 N.E.2d 412, 413 (1960); People v. Washington, 26 Ill. 2d 207, 209 , 186 N.E.2d 259, 261 (1962); People v. Cole, 30 Ill. 2d 375, 379 , 196 N.E.2d 691, 694 (1964); People v. Armstrong, 41 Ill. 2d 390, 399 , 243 N.E.2d 825, 830 (1968); People v. Hubbard, 55 Ill. 2d 142, 147-48 , 302 N.E.2d 609, 612 (1973); Kessler, 57 Ill. 2d at 497 , 315 N.E.2d at 32 ; People v. Terry,	2	2
People v. Hubbardgreen ill · 1973 · cited in 2 Illinois opinions naming this issue, 2014–2014	2	2
The PEOPLE v. Torresgreen ill · 1960 · cited in 2 Illinois opinions naming this issue, 2014–2014	2	2
People v. Rudeckigreen ill · 1923 · cited in 2 Illinois opinions naming this issue, 2014–2014 2 sentences 2014See, e.g., People v. Rudecki, 309 Ill. 125, 129 , 140 N.E. 832, 833 (1923); Tarver, 381 Ill. at 416 , 45 N.E.2d at 632 ; People v. Rybka, 16 Ill. 2d 394, 405 , 158 N.E.2d 17, 22 (1959); People v. Torres, 19 Ill. 2d 497, 499 , 167 N.E.2d 412, 413 (1960); People v. Washington, 26 Ill. 2d 207, 209 , 186 N.E.2d 259, 261 (1962); People v. Cole, 30 Ill. 2d 375, 379 , 196 N.E.2d 691, 694 (1964); People v. Armstrong, 41 Ill. 2d 390, 399 , 243 N.E.2d 825, 830 (1968); People v. Hubbard, 55 Ill. 2d 142, 147-48 , 302 N.E.2d 609, 612 (1973); Kessler, 57 Ill. 2d at 497 , 315 N.E.2d at 32 ; People v. Terry, 2014See, e.g., People v. Rudecki, 309 Ill. 125, 129 , 140 N.E. 832, 833 (1923); Tarver, 381 Ill. at 416 , 45 N.E.2d at 632 ; People v. Rybka, 16 Ill. 2d 394, 405 , 158 N.E.2d 17, 22 (1959); People v. Torres, 19 Ill. 2d 497, 499 , 167 N.E.2d 412, 413 (1960); People v. Washington, 26 Ill. 2d 207, 209 , 186 N.E.2d 259, 261 (1962); People v. Cole, 30 Ill. 2d 375, 379 , 196 N.E.2d 691, 694 (1964); People v. Armstrong, 41 Ill. 2d 390, 399 , 243 N.E.2d 825, 830 (1968); People v. Hubbard, 55 Ill. 2d 142, 147-48 , 302 N.E.2d 609, 612 (1973); Kessler, 57 Ill. 2d at 497 , 315 N.E.2d at 32 ; People v. Terry,	2	2
People v. Walstongreen illappct · 2008 · cited in 2 Illinois opinions naming this issue, 2011–2011	2	2
People v. Lenleygreen illappct · 2003 · cited in 2 Illinois opinions naming this issue, 2005–2005	2	2
People v. Williamsgreen ill · 2000 · cited in 2 Illinois opinions naming this issue, 2003–2003	2	2
People v. Martingreen illappct · 1995 · cited in 2 Illinois opinions naming this issue, 1998–1998	2	2
People v. Kesslergreen ill · 1974 · cited in 16 Illinois opinions naming this issue, 1984–2025 2 sentences 2025“A common design can -10- 1-23-0943 be inferred from the circumstances surrounding the perpetration of the unlawful conduct.” People v. Petrov, 2023 IL App (1st) 160498 , ¶ 96. ¶ 31 People v. Kessler, 57 Ill. 2d 493 (1974), provides a textbook application of the common- design rule. 2023People v. Perez, 189 Ill. 2d 254, 267 (2000). ¶ 77 Although factually unrelated, People v. Kessler, 57 Ill. 2d 493 (1974), is a “textbook application of the common-design rule.” Fernandez, 2014 IL 115527, ¶ 14 .	1	16
People v. Marxgreen ill · 1919 · cited in 2 Illinois opinions naming this issue, 2017–2018 2 sentences 2018See also People v. Fernandez, 2014 IL 115527, ¶ 13 ; In re W.C., 167 Ill. 2d 307, 337 (1995); People v. J.H., 136 Ill. 2d 1 , 17 -8- (1990); Terry, 99 Ill. 2d at 514 ; People v. Cole, 30 Ill. 2d 375 (1964); People v. Marx, 291 Ill. 40, 48 (1919); Hamilton v. People, 113 Ill. 34 (1885). 2017See also People v. Fernandez , 2014 IL 115527 , ¶ 13, 379 Ill.Dec. 68 , 6 N.E.3d 145 ; In re W.C. , 167 Ill. 2d 307 , 337, 212 Ill.Dec. 563 , 657 N.E.2d 908 (1995) ; People v. J.H. , 136 Ill. 2d 1 , 17, 143 Ill.Dec. 889 , 554 N.E.2d 961 (1990) ; Terry , 99 Ill. 2d at 514 , 77 Ill.Dec. 442 , 460 N.E.2d 746 ; People v. Cole , 30 Ill. 2d 375 , 196 N.E.2d 691 (1964) ; People v. Marx , 291 Ill. 40 , 48, 125 N.E. 719 (1919) ; Hamilton v. People , 113 Ill. 34 (1885).	1	2
People v. Stancielgreen ill · 1992 · cited in 2 Illinois opinions naming this issue, 1995–1995	1	2
People v. Houstongreen illappct · 1994 · cited in 1 Illinois opinions naming this issue, 2024–2024	1	1
People v. McCoygreen illappct · 2003 · cited in 1 Illinois opinions naming this issue, 2023–2023	1	1
People v. Taylorgreen ill · 1995 · cited in 1 Illinois opinions naming this issue, 2022–2022	1	1
People v. Wheelergreen ill · 2007 · cited in 1 Illinois opinions naming this issue, 2021–2021	1	1
People v. Doolangreen illappct · 2016 · cited in 1 Illinois opinions naming this issue, 2020–2020	1	1
People v. Johnsongreen illappct · 2014 · cited in 1 Illinois opinions naming this issue, 2020–2020	1	1
People v. Gilliamgreen ill · 1996 · cited in 1 Illinois opinions naming this issue, 2012–2012	1	1

Distinguished, questioned or overruled (0)

Case	Negative	Cited
No negative-treatment citations attached to this issue in Illinois. Read the followed side critically anyway.

Also cited on this issue (31)

Case	Cited	Years
Hamilton v. People green ill · 1885 2 sentences 2014Such being the case, whatever was done by one, in contemplation of law was done by all, and all are therefore equally responsible." Id. at 37-38 . ¶ 53 In the almost 130 years since Hamilton, the supreme court has repeatedly rejected - 17 - shared intent as an element of the common-design rule. 2014Such being the case, whatever was done by one, in contemplation of law was done by all, and all are therefore equally responsible.” Id. at 37-38 . ¶ 53 In the almost 130 years since Hamilton, the supreme court has repeatedly rejected shared intent as an element of the common-design rule.	4	2014–2018
The People v. Tarver green ill · 1942 2 sentences 2014See, e.g., People v. Rudecki, 309 Ill. 125, 129 , 140 N.E. 832, 833 (1923); Tarver, 381 Ill. at 416 , 45 N.E.2d at 632 ; People v. Rybka, 16 Ill. 2d 394, 405 , 158 N.E.2d 17, 22 (1959); People v. Torres, 19 Ill. 2d 497, 499 , 167 N.E.2d 412, 413 (1960); People v. Washington, 26 Ill. 2d 207, 209 , 186 N.E.2d 259, 261 (1962); People v. Cole, 30 Ill. 2d 375, 379 , 196 N.E.2d 691, 694 (1964); People v. Armstrong, 41 Ill. 2d 390, 399 , 243 N.E.2d 825, 830 (1968); People v. Hubbard, 55 Ill. 2d 142, 147-48 , 302 N.E.2d 609, 612 (1973); Kessler, 57 Ill. 2d at 497 , 315 N.E.2d at 32 ; People v. Terry, 2014See, e.g., People v. Rudecki, 309 Ill. 125, 129 , 140 N.E. 832, 833 (1923); Tarver, 381 Ill. at 416 , 45 N.E.2d at 632 ; People v. Rybka, 16 Ill. 2d 394, 405 , 158 N.E.2d 17, 22 (1959); People v. Torres, 19 Ill. 2d 497, 499 , 167 N.E.2d 412, 413 (1960); People v. Washington, 26 Ill. 2d 207, 209 , 186 N.E.2d 259, 261 (1962); People v. Cole, 30 Ill. 2d 375, 379 , 196 N.E.2d 691, 694 (1964); People v. Armstrong, 41 Ill. 2d 390, 399 , 243 N.E.2d 825, 830 (1968); People v. Hubbard, 55 Ill. 2d 142, 147-48 , 302 N.E.2d 609, 612 (1973); Kessler, 57 Ill. 2d at 497 , 315 N.E.2d at 32 ; People v. Terry,	4	2014–2014
People v. Phillips green illappct · 2012 2 sentences 2021Here, the evidence supports defendant’s accountability under the common-design rule, where defendant agreed in her statement that she knew Brown might shoot Carothers and admitted that she knew Brown would do something “bad.” ¶ 76 Additionally, our supreme court in Fernandez overruled People v. Phillips, 2012 IL App (1st) 101923 , which relied on a “misunderstanding” of Taylor to hold that a defendant was not culpable for a shooting where he intended to help someone commit a crime against the victim but did not know the person possessed a firearm. 2014Id. ¶ 21. ¶ 48 The Fernandez court specifically overruled Phillips, 2012 IL App (1st) 101923 , which the Johnson court relied upon.	3	2014–2021
People v. Walls green illappct · 2022 2 sentences 2024People v. Fernandez, 2014 IL 115527, ¶ 13 ; Walls, 2022 IL App (1st) 200167, ¶ 20 . 2024People v. Fernandez, 2014 IL 115527, ¶ 13 ; Walls, 2022 IL App (1st) 200167, ¶ 20 .	2	2024–2024
People v. Jackson green illappct · 2020 2 sentences 2023Here, defendant claims that the trial court’s answer “invited the jury to come up with any offense that it believed [defendant] committed or planned to commit, and convict [defendant] of first degree murder under that theory.” We do not find this argument persuasive. ¶ 73 Under the common-design rule, to hold a defendant accountable for another’s conduct, the evidence must demonstrate that a defendant “attache[d] himself to a group bent on illegal acts with knowledge of its design.” People v. Jackson, 2020 IL App (4th) 170036, ¶ 49 . “ ‘With knowledge of its design’ means only that a person wh 2023Here, defendant claims that the trial court’s answer “invited the jury to come up with any offense that it believed [defendant] committed or planned to commit, and convict [defendant] of first degree murder under that theory.” We do not find this argument persuasive. ¶ 73 Under the common-design rule, to hold a defendant accountable for another’s conduct, the evidence must demonstrate that a defendant “attache[d] himself to a group bent on illegal acts with knowledge of its design.” People v. Jackson, 2020 IL App (4th) 170036, ¶ 49 . “ ‘With knowledge of its design’ means only that a person wh	2	2022–2023
People v. James green illappct · 2017 2 sentences 2021EPILOGUE ¶ 68 Although the Illinois Appellate Court has followed the supreme court’s guidance on legal accountability since the Fernandez decision (see, e.g., People v. Williams, 2016 IL App (1st) 133459, ¶¶ 45-48 , 64 N.E.3d 1086 ; People v. James, 2017 IL App (1st) 143391, ¶¶ 56-57 , 93 N.E.3d 626 ; People v. Cowart, 2017 IL App (1st) 113085-B , ¶¶ 38-40, 81 N.E.3d 1023 ; Ealy, 2019 IL App (1st) 161575, ¶¶ 31-33 ; People v. Malcolm, 2015 IL App (1st) 133406, ¶¶ 40, 43 , 39 N.E.3d 98 ), defendants continue to raise “the bogus shared-intent requirement of the common-design rule” (Phillips, 201 2021EPILOGUE ¶ 68 Although the Illinois Appellate Court has followed the supreme court’s guidance on legal accountability since the Fernandez decision (see, e.g., People v. Williams, 2016 IL App (1st) 133459, ¶¶ 45-48 , 64 N.E.3d 1086 ; People v. James, 2017 IL App (1st) 143391, ¶¶ 56-57 , 93 N.E.3d 626 ; People v. Cowart, 2017 IL App (1st) 113085-B , ¶¶ 38-40, 81 N.E.3d 1023 ; Ealy, 2019 IL App (1st) 161575, ¶¶ 31-33 ; People v. Malcolm, 2015 IL App (1st) 133406, ¶¶ 40, 43 , 39 N.E.3d 98 ), defendants continue to raise “the bogus shared-intent requirement of the common-design rule” (Phillips, 201	2	2020–2021
People v. Ealy green illappct · 2019 2 sentences 2021EPILOGUE ¶ 68 Although the Illinois Appellate Court has followed the supreme court’s guidance on legal accountability since the Fernandez decision (see, e.g., People v. Williams, 2016 IL App (1st) 133459, ¶¶ 45-48 , 64 N.E.3d 1086 ; People v. James, 2017 IL App (1st) 143391, ¶¶ 56-57 , 93 N.E.3d 626 ; People v. Cowart, 2017 IL App (1st) 113085-B , ¶¶ 38-40, 81 N.E.3d 1023 ; Ealy, 2019 IL App (1st) 161575, ¶¶ 31-33 ; People v. Malcolm, 2015 IL App (1st) 133406, ¶¶ 40, 43 , 39 N.E.3d 98 ), defendants continue to raise “the bogus shared-intent requirement of the common-design rule” (Phillips, 201 2020EPILOGUE ¶ 68 Although the Illinois Appellate Court has followed the supreme court’s guidance on legal accountability since the Fernandez decision (see, e.g., People v. Williams, 2016 IL App (1st) 133459, ¶¶ 45-48 , 64 N.E.3d 1086 ; People v. James, 2017 IL App (1st) 143391, ¶¶ 56-57 , 93 N.E.3d 626 ; People v. Cowart, 2017 IL App (1st) 113085-B , ¶¶ 38-40, 81 N.E.3d 1023 ; Ealy, 2019 IL App (1st) 161575, ¶¶ 31-33 ; People v. Malcolm, 2015 IL App (1st) 133406, ¶¶ 40, 43 , 39 N.E.3d 98 ), defendants continue to raise “the bogus shared-intent requirement of the common- design rule” (Phillips, 20	2	2020–2021
People v. Williams green illappct · 2016 2 sentences 2021EPILOGUE ¶ 68 Although the Illinois Appellate Court has followed the supreme court’s guidance on legal accountability since the Fernandez decision (see, e.g., People v. Williams, 2016 IL App (1st) 133459, ¶¶ 45-48 , 64 N.E.3d 1086 ; People v. James, 2017 IL App (1st) 143391, ¶¶ 56-57 , 93 N.E.3d 626 ; People v. Cowart, 2017 IL App (1st) 113085-B , ¶¶ 38-40, 81 N.E.3d 1023 ; Ealy, 2019 IL App (1st) 161575, ¶¶ 31-33 ; People v. Malcolm, 2015 IL App (1st) 133406, ¶¶ 40, 43 , 39 N.E.3d 98 ), defendants continue to raise “the bogus shared-intent requirement of the common-design rule” (Phillips, 201 2021EPILOGUE ¶ 68 Although the Illinois Appellate Court has followed the supreme court’s guidance on legal accountability since the Fernandez decision (see, e.g., People v. Williams, 2016 IL App (1st) 133459, ¶¶ 45-48 , 64 N.E.3d 1086 ; People v. James, 2017 IL App (1st) 143391, ¶¶ 56-57 , 93 N.E.3d 626 ; People v. Cowart, 2017 IL App (1st) 113085-B , ¶¶ 38-40, 81 N.E.3d 1023 ; Ealy, 2019 IL App (1st) 161575, ¶¶ 31-33 ; People v. Malcolm, 2015 IL App (1st) 133406, ¶¶ 40, 43 , 39 N.E.3d 98 ), defendants continue to raise “the bogus shared-intent requirement of the common-design rule” (Phillips, 201	2	2020–2021
People v. J.H. green ill · 1990 2 sentences 2018See also People v. Fernandez, 2014 IL 115527, ¶ 13 ; In re W.C., 167 Ill. 2d 307, 337 (1995); People v. J.H., 136 Ill. 2d 1 , 17 -8- (1990); Terry, 99 Ill. 2d at 514 ; People v. Cole, 30 Ill. 2d 375 (1964); People v. Marx, 291 Ill. 40, 48 (1919); Hamilton v. People, 113 Ill. 34 (1885). 2017See also People v. Fernandez , 2014 IL 115527 , ¶ 13, 379 Ill.Dec. 68 , 6 N.E.3d 145 ; In re W.C. , 167 Ill. 2d 307 , 337, 212 Ill.Dec. 563 , 657 N.E.2d 908 (1995) ; People v. J.H. , 136 Ill. 2d 1 , 17, 143 Ill.Dec. 889 , 554 N.E.2d 961 (1990) ; Terry , 99 Ill. 2d at 514 , 77 Ill.Dec. 442 , 460 N.E.2d 746 ; People v. Cole , 30 Ill. 2d 375 , 196 N.E.2d 691 (1964) ; People v. Marx , 291 Ill. 40 , 48, 125 N.E. 719 (1919) ; Hamilton v. People , 113 Ill. 34 (1885).	2	2017–2018
People v. Hudson green ill · 2006 2 sentences 2014By setting out to commit a crime with Grimes, defendant rendered himself legally accountable for Grimes's shooting of Maclin. ¶ 45 Like the felony-murder doctrine, under which a defendant may be liable for first degree murder even when his cofelon is killed by a police officer (People v. Hudson, 222 Ill. 2d 392 , 856 N.E.2d 1078 (2006)) or when a resisting victim accidentally kills an innocent bystander (People v. Lowery, 178 Ill. 2d 462 , 687 N.E.2d 973 (1997)), the common-design rule provides harsh medicine for those who willingly join with others to engage in criminal acts. 2014By setting out to commit a crime with Grimes, defendant rendered himself legally accountable for Grimes's shooting of Maclin. ¶ 45 Like the felony-murder doctrine, under which a defendant may be liable for first degree murder even when his cofelon is killed by a police officer (People v. Hudson, 222 Ill. 2d 392 , 856 N.E.2d 1078 (2006)) or when a resisting victim accidentally kills an innocent bystander (People v. Lowery, 178 Ill. 2d 462 , 687 N.E.2d 973 (1997)), the common-design rule provides harsh medicine for those who willingly join with others to engage in criminal acts.	2	2014–2014
People v. Lowery green ill · 1997 2 sentences 2014By setting out to commit a crime with Grimes, defendant rendered himself legally accountable for Grimes's shooting of Maclin. ¶ 45 Like the felony-murder doctrine, under which a defendant may be liable for first degree murder even when his cofelon is killed by a police officer (People v. Hudson, 222 Ill. 2d 392 , 856 N.E.2d 1078 (2006)) or when a resisting victim accidentally kills an innocent bystander (People v. Lowery, 178 Ill. 2d 462 , 687 N.E.2d 973 (1997)), the common-design rule provides harsh medicine for those who willingly join with others to engage in criminal acts. 2014By setting out to commit a crime with Grimes, defendant rendered himself legally accountable for Grimes's shooting of Maclin. ¶ 45 Like the felony-murder doctrine, under which a defendant may be liable for first degree murder even when his cofelon is killed by a police officer (People v. Hudson, 222 Ill. 2d 392 , 856 N.E.2d 1078 (2006)) or when a resisting victim accidentally kills an innocent bystander (People v. Lowery, 178 Ill. 2d 462 , 687 N.E.2d 973 (1997)), the common-design rule provides harsh medicine for those who willingly join with others to engage in criminal acts.	2	2014–2014
In Re AR green illappct · 1998	2	1998–1998
People v. Allen green ill · 1974	2	1995–1995
People v. Petrov green illappct · 2023	1	2025–2025
People v. Hancock green illappct · 2014	1	2024–2024
People v. Garcia green illappct · 2019	1	2020–2020
People v. Rebollar-Vergara green illappct · 2019	1	2019–2019
People v. Salazar green illappct · 2014	1	2014–2014
People v. Taylor green ill · 1999	1	2012–2012
People v. Homes green illappct · 1995	1	1995–1995
People v. Marshall green ill · 1947	1	1995–1995
People v. Foster green illappct · 1990	1	1993–1993
People v. Hoard green illappct · 1993	1	1993–1993
People v. Larson green illappct · 1985	1	1993–1993
People v. Clay green illappct · 1984	1	1993–1993
People v. Moreno green illappct · 1992	1	1993–1993
Esser v. Tripodi neutral scotus · 1974	1	1988–1988
Cross v. Church neutral scotus · 1974	1	1988–1988
The People v. Hill green ill · 1968	1	1975–1975
People v. Kriston neutral illappct · 1973	1	1975–1975
Miranda v. Arizona green scotus · 1966	1	1969–1969

Statutes the citing opinions construe

IL § 720 ILCS 5/5-2 (46) IL § 720 ILCS 5/9-1 (22) IL § 720 ILCS 5/24-1.2 (8) IL § 720 ILCS 5/8-4 (6) IL § 55 ILCS 5/4-2002 (5) IL § 730 ILCS 5/5-8-1 (5) IL § 720 ILCS 5/12-3.05 (4) IL § 720 ILCS 5/12-4 (3) IL § 720 ILCS 5/18-2 (3) IL § 720 ILCS 5/24-1 (3) IL § 720 ILCS 5/4-5 (3) IL § 730 ILCS 5/5-4.5-25 (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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