Already have an account? Sign in instead.
You stay signed in for 30 days on this browser.
Continue with Google Continue with MicrosoftNo account yet? Create a free one.
We sent a six-digit code.
It expires in ten minutes, works once, and only in this browser. Five wrong tries void it. Send another code.
Your account is live and the Cloudflare checks are off for this browser.
68 Illinois opinions name it 2 courts 2010–2026 28 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. Herrongreen2 sentences2026People v. Herron, 215 Ill. 2d 167, 177 (2005); Ill. 2021Similarly, Rule 451(c) creates a limited exception to the general forfeiture rule to correct “grave errors” and errors in cases “so factually close that fundamental fairness requires that the jury be properly instructed.” People v. Herron, 215 Ill. 2d 167, 175 (2005). | 22 | 26 |
People v. Hilliergreen2 sentences2020People v. Hillier, 237 Ill. 2d 539, 545 (2010)). ¶ 21 The plain-error doctrine serves as “ ‘a narrow and limited exception’ ” to the general forfeiture rule. 2015Id. at 545 . ¶ 24 Our supreme court has clarified on many occasions that the plain error doctrine is a narrow and limited exception to the general forfeiture rule. | 10 | 18 |
People v. Pastorinogreen2 sentences2023People v. Szabo, 113 Ill. 2d 83, 94 (1986) (quoting People v. Pastorino, 91 Ill. 2d 178, 188 (1982)). 2020People v. Szabo, 113 Ill. 2d 83, 94 (1986) (quoting People v. Pastorino, 91 Ill. 2d 178, 188 (1982)). | 5 | 6 |
People v. Szabogreen2 sentences2023People v. Szabo, 113 Ill. 2d 83, 94 (1986) (quoting People v. Pastorino, 91 Ill. 2d 178, 188 (1982)). 2020People v. Szabo, 113 Ill. 2d 83, 94 (1986) (quoting People v. Pastorino, 91 Ill. 2d 178, 188 (1982)). | 5 | 6 |
People v. Piatkowskigreen2 sentences2022The exception is to be invoked only where a clear or obvious error occurred and: (1) the evidence is so closely balanced that the error alone threatened to tip the scales of justice against the defendant, regardless of the seriousness of the error, or (2) the error is so serious that it affected the fairness of defendant’s trial and challenged the integrity of the judicial process, regardless of the closeness of the evidence.” People v. Piatkowski, 225 Ill. 2d 551, 565 (2007). 2022The exception is to be invoked only where a clear or obvious error occurred and: (1) the evidence is so closely balanced that the error alone threatened to tip the scales of justice against the defendant, regardless of the seriousness of the error, or (2) the error is so serious that it affected the fairness of defendant’s trial and challenged the integrity of the judicial process, regardless of the closeness of the evidence.” People v. Piatkowski, 225 Ill. 2d 551, 565 (2007). | 4 | 4 |
People v. Hamptongreen2 sentences2016People v. Hampton, 149 Ill. 2d 71, 100 (1992). 2016People v. Hillier, 237 Ill. 2d 539, 545 (2010); see also People v. Herron, 215 Ill. 2d 167, 177 (2005) (quoting People v. Hampton, 149 Ill. 2d 71, 100 (1992) (same)). | 2 | 2 |
People v. Walkergreen2 sentences2014People v. Walker, 232 Ill. 2d 113, 124 (2009). 2014People v. Walker, 232 Ill. 2d 113, 124 (2009). | 2 | 2 |
People v. Thompsongreen2 sentences2023Thompson, 238 Ill. 2d at 611 . ¶ 104 Once again, the defendant argues that we should review this issue under the plain-error exception to the general forfeiture rule. 2019People v. Thompson, 238 Ill. 2d 598, 613 (2010) (quoting People v. Piatkowksi, 225 Ill. 2d 551, 565 (2007)). | 1 | 2 |
People v. Garciagreen2 sentences2020People v. Garcia, 2012 IL App (1st) 103590, ¶ 121 (citing People v. Piatkowski, 225 Ill. 2d 551, 565 (2007)). 2019People v. Garcia, 2012 IL App (1st) 103590, ¶ 121 . | 1 | 2 |
People v. Pricegreen1 sentence2025See People v. Thompson, 2015 IL 118151, ¶¶ 15, 32 ; see also People v. Price, 2016 IL 118613, ¶¶ 30-31 . | 1 | 1 |
People v. Thompsongreen1 sentence2025See People v. Thompson, 2015 IL 118151, ¶¶ 15, 32 ; see also People v. Price, 2016 IL 118613, ¶¶ 30-31 . | 1 | 1 |
People v. Johnsongreen1 sentence2024People v. Johnson, 238 Ill. 2d 478, 484 (2010). | 1 | 1 |
People v. Smithgreen1 sentence2023People v. Wilson, 2014 IL App (1st) 113570, ¶ 46 (“[W]e do not consider arguments related to strategy when reviewing first-stage postconviction petitions.”); People v. Smith, 326 Ill. App. 3d 831, 839-40 (2001) (“Substantive questions relating to the issues raised in the - 19 - ¶ 45 Despite clear black letter law that creates an exception to the general forfeiture rule for an ineffective assistance of counsel claim interlocking with a guilty plea, confusion nonetheless abounds. | 1 | 1 |
People v. Pickettgreen1 sentence2022People v. Pickett, 54 Ill. 2d 280, 282 (1973). ¶ 19 The plain error rule does not call for the review of all forfeited errors. | 1 | 1 |
People v. Mooregreen1 sentence2020See People v. Moore, 2020 IL App (1st) 182535, ¶ 19 (the plain error doctrine is a narrow and limited exception to the general forfeiture rule). | 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. Walsh
green
2 sentences2025“Plain error is a limited and narrow exception to the general forfeiture rule.” Walsh, 2016 IL App (2d) 140357, ¶ 17 . 2023Nevertheless, he contends that we may consider the issue (1) under the plain-error rule or (2) because defense counsel was ineffective for failing to raise the issue in the trial court. ¶ 16 “ ‘Plain error is a limited and narrow exception to the general forfeiture rule.’ ” Id. ¶ 14 (quoting People v. Walsh, 2016 IL App (2d) 140357, ¶ 17 ). “ ‘To obtain relief under the plain- error rule, a defendant must show that a clear or obvious error occurred.’ ” Id. (quoting Walsh, 2016 IL App (2d) 140357, ¶ 17 ). “ ‘If a clear or obvious error is identified, a defendant may obtain -5- relief if the err | 7 | 2020–2025 |
People v. Jackson
green
2 sentences2022People v. Jackson, 2020 IL 124112, ¶ 81 , 162 N.E.3d 223 ; see also People v. Herron, 215 Ill. 2d 167, 177 , 830 N.E.2d 467, 474 (2005). 2022People v. Jackson, 2020 IL 124112, ¶ 81 , 162 N.E.3d 223 ; see also People v. Herron, 215 Ill. 2d 167, 177 , 830 N.E.2d 467, 474 (2005). | 4 | 2021–2022 |
People v. Aguilar
green
1 sentence2025The Aguilar court noted that it made “no finding, express or implied, with respect to the constitutionality or unconstitutionality of any other section or subsection of the AUUW statute.” Id. ¶ 22 n.3. 2 exception to the general forfeiture rule, however, provides that a party may facially attack a statute’s constitutionality on appeal even if the party did not raise the issue in the trial court and the limitation period for filing a section 2-1401 petition has expired. | 1 | 2025–2025 |
People v. Johnson
green
1 sentence2023Nevertheless, he contends that we may consider the issue (1) under the plain-error rule or (2) because defense counsel was ineffective for failing to raise the issue in the trial court. ¶ 16 “ ‘Plain error is a limited and narrow exception to the general forfeiture rule.’ ” Id. ¶ 14 (quoting People v. Walsh, 2016 IL App (2d) 140357, ¶ 17 ). “ ‘To obtain relief under the plain- error rule, a defendant must show that a clear or obvious error occurred.’ ” Id. (quoting Walsh, 2016 IL App (2d) 140357, ¶ 17 ). “ ‘If a clear or obvious error is identified, a defendant may obtain -5- relief if the err | 1 | 2023–2023 |
People v. Roman
green
2 sentences2023“To obtain relief, defendant must first show that there was a clear or obvious error.” 10 Id. 2023“Under the narrow and limited plain error exception to the general forfeiture rule, a reviewing court may consider forfeited errors where the evidence was closely balanced or where the error was so egregious that defendant was deprived of a substantial right and thus a fair trial.” People v. Roman, 2013 IL App (1st) 102853, ¶ 19 . | 1 | 2023–2023 |
People v. Williams
green
1 sentence2021People v. Williams, 2018 IL App (4th) 150759, ¶ 16 . ¶ 22 It is important to note that the doctrine of plain error is not a general savings clause to be used to preserve all errors affecting substantial rights not previously brought to the trial court’s attention, but it is a narrow and limited exception to the general forfeiture rule. | 1 | 2021–2021 |
People v. Sebby
green
1 sentence2018Id. | 1 | 2018–2018 |
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.