police error (Illinois) · Go Syfert
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police error in Illinois

69 Illinois opinions name it 3 courts 1971–2025 12 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 (15)

CaseFollowedCited
Nix v. Williamsgreen
scotus · 1984 · cited in 25 Illinois opinions naming this issue, 1991–2025
2 sentences

2025And that search would have uncovered the gun in the trunk. ¶ 30 The doctrine of “inevitable discovery” provides that evidence obtained in an illegal search will not be suppressed if it “ ‘would inevitably have been discovered without reference to the police error or misconduct.’ ” People v. Sutherland, 223 Ill. 2d 187, 227-28 (2006) (quoting Nix v. Williams, 467 U.S. 431, 448 (1984)).

2025The inevitable discovery doctrine provides “that evidence obtained in violation of a defendant’s constitutional rights and which otherwise would be inadmissible at trial may be admitted if the prosecution is able to show that the challenged evidence ‘would inevitably have been discovered without reference to the police error or misconduct.’ ” Id. at 142 (1991) (quoting Nix v. Williams, 467 U.S. 431, 448 (1984)). ¶ 62 Defendant argues that the inevitable discovery doctrine does not apply because the information the officers used to secure the warrant was obtained after their unlawful entry into

2125
People v. Sutherlandgreen
ill · 2006 · cited in 20 Illinois opinions naming this issue, 2010–2025
2 sentences

2025And that search would have uncovered the gun in the trunk. ¶ 30 The doctrine of “inevitable discovery” provides that evidence obtained in an illegal search will not be suppressed if it “ ‘would inevitably have been discovered without reference to the police error or misconduct.’ ” People v. Sutherland, 223 Ill. 2d 187, 227-28 (2006) (quoting Nix v. Williams, 467 U.S. 431, 448 (1984)).

2024“This exception permits evidence, that would otherwise be inadmissible at trial, to be admitted where the State can show that such evidence ‘would inevitably have been discovered without reference to the police error or misconduct.’ ” Sutherland, 223 Ill. 2d 187, 228 (quoting Nix v. Williams, 467 U.S. 431, 448 (1984)). ¶ 32 As the State argues, defendant’s vehicle would have inevitably been subject to an inventory search before it was impounded.

1820
People v. Edwardsgreen
ill · 1991 · cited in 9 Illinois opinions naming this issue, 1992–2025
2 sentences

2025The inevitable discovery doctrine provides “that evidence obtained in violation of a defendant’s constitutional rights and which otherwise would be inadmissible at trial may be admitted if the prosecution is able to show that the challenged evidence ‘would inevitably have been discovered without reference to the police error or misconduct.’ ” Id. at 142 (1991) (quoting Nix v. Williams, 467 U.S. 431, 448 (1984)). ¶ 62 Defendant argues that the inevitable discovery doctrine does not apply because the information the officers used to secure the warrant was obtained after their unlawful entry into

2004Under that rule, “evidence that otherwise would be inadmissible may be admitted if the prosecution can show that the evidence ‘ “would inevitably have been discovered without reference to the police error or misconduct.” ’ ” People v. Mitchell, 189 Ill. 2d 312, 342 , 727 N.E.2d 254, 272 (2000), quoting People v. Edwards, 144 Ill. 2d 108, 142 , 579 N.E.2d 336, 349 (1991), quoting Nix v. Williams, 467 U.S. 431, 448 , 81 L.

89
United States v. Eugene L. Dawdygreen
ca8 · 1995 · cited in 3 Illinois opinions naming this issue, 2015–2015
2 sentences

2015See, e.g., United States v. Dawdy, 46 F.3d 1427, 1430-31 (8th Cir. 1995) (suppression denied when resistance provided independent grounds for arrest); State v. Williams, 926 A.2d 340 (N.J. 2007) (interpreting New Jersey’s obstruction statute); Reynolds v. State, 634 S.E.2d 842, 845 (Ga. Ct. App. 2006) (act of fleeing was a separate crime). ¶ 57 Finally, the State contends that the evidence was nevertheless admissible under People v. Henderson, 2013 IL 114040 , a case that considered whether the abandonment of a gun during flight from officers broke the causal connection between an illegal stop

2015See, e.g., United States v. Dawdy, 46 F.3d 1427, 1430-31 (8th Cir. 1995) (suppression denied when resistance provided independent grounds for arrest); State v. Williams, 926 A.2d 340 (N.J. 2007) (interpreting New Jersey’s obstruction statute); Reynolds v. State, 634 S.E.2d 842, 845 (Ga. Ct. App. 2006) (act of fleeing was a separate crime). ¶ 57 Finally, the State contends that the evidence was nevertheless admissible under People v. Henderson, 2013 IL 114040 , a case that considered whether the abandonment of a gun during flight from officers broke the causal connection between an illegal stop

33
Reynolds v. Stategreen
gactapp · 2006 · cited in 3 Illinois opinions naming this issue, 2015–2015
2 sentences

2015See, e.g., United States v. Dawdy, 46 F.3d 1427, 1430-31 (8th Cir. 1995) (suppression denied when resistance provided independent grounds for arrest); State v. Williams, 926 A.2d 340 (N.J. 2007) (interpreting New Jersey’s obstruction statute); Reynolds v. State, 634 S.E.2d 842, 845 (Ga. Ct. App. 2006) (act of fleeing was a separate crime). ¶ 57 Finally, the State contends that the evidence was nevertheless admissible under People v. Henderson, 2013 IL 114040 , a case that considered whether the abandonment of a gun during flight from officers broke the causal connection between an illegal stop

2015See, e.g., United States v. Dawdy, 46 F.3d 1427, 1430-31 (8th Cir. 1995) (suppression denied when resistance provided independent grounds for arrest); State v. Williams, 926 A.2d 340 (N.J. 2007) (interpreting New Jersey’s obstruction statute); Reynolds v. State, 634 S.E.2d 842, 845 (Ga. Ct. App. 2006) (act of fleeing was a separate crime). ¶ 57 Finally, the State contends that the evidence was nevertheless admissible under People v. Henderson, 2013 IL 114040 , a case that considered whether the abandonment of a gun during flight from officers broke the causal connection between an illegal stop

33
People v. Gantergreen
illappct · 1977 · cited in 3 Illinois opinions naming this issue, 2013–2014
2 sentences

2014People v. Ganter, 56 Ill.

2013People v. Ganter, 56 Ill.

33
People v. Mitchellgreen
ill · 2000 · cited in 3 Illinois opinions naming this issue, 2004–2006
2 sentences

2004Under that rule, “evidence that otherwise would be inadmissible may be admitted if the prosecution can show that the evidence ‘ “would inevitably have been discovered without reference to the police error or misconduct.” ’ ” People v. Mitchell, 189 Ill. 2d 312, 342 , 727 N.E.2d 254, 272 (2000), quoting People v. Edwards, 144 Ill. 2d 108, 142 , 579 N.E.2d 336, 349 (1991), quoting Nix v. Williams, 467 U.S. 431, 448 , 81 L.

2004Under that rule, “evidence that otherwise would be inadmissible may be admitted if the prosecution can show that the evidence ‘ “would inevitably have been discovered without reference to the police error or misconduct.” ’ ” People v. Mitchell, 189 Ill. 2d 312, 342 , 727 N.E.2d 254, 272 (2000), quoting People v. Edwards, 144 Ill. 2d 108, 142 , 579 N.E.2d 336, 349 (1991), quoting Nix v. Williams, 467 U.S. 431, 448 , 81 L.

33
Provena Covenant Medical Center v. Department of Revenuegreen
ill · 2010 · cited in 2 Illinois opinions naming this issue, 2014–2014
2 sentences

2014See Provena Covenant Medical Center, 236 Ill. 2d at 386-87 .

2014See Provena Covenant Medical Center, 236 Ill. 2d at 368-87 .

22
State v. Andersongreen
wisctapp · 1987 · cited in 2 Illinois opinions naming this issue, 2005–2005
2 sentences

2005See, e.g. , Anderson , 142 Wis. 2d at 169 , 417 N.W.2d at 414 (holding that the exception applies when a seizure occurs, the police were engaged in " bona fide community caretaker activity," and the public's interest in the police activity in question outweighs the intrusion on the individual's right to be let alone).

2005See, e.g., Anderson, 142 Wis. 2d at 169 , 417 N.W.2d at 414 (holding that the exception applies when a seizure occurs, the police were engaged in “bona fide community caretaker activity,” and the public’s interest in the police activity in question outweighs the intrusion on the individual’s right to be let alone).

22
People v. Hundleygreen
ill · 1993 · cited in 1 Illinois opinions naming this issue, 2024–2024
1 sentence

2024An inventory search is a “judicially created exception to the warrant requirement of the fourth amendment.” People v. Hundley, 156 Ill.2d 135, 138 (1993); see also Florida v. Wells, 495 U.S. 1, 4 (1990).

11
Florida v. Wellsgreen
scotus · 1990 · cited in 1 Illinois opinions naming this issue, 2024–2024
1 sentence

2024An inventory search is a “judicially created exception to the warrant requirement of the fourth amendment.” People v. Hundley, 156 Ill.2d 135, 138 (1993); see also Florida v. Wells, 495 U.S. 1, 4 (1990).

11
People v. R.C.green
ill · 1985 · cited in 1 Illinois opinions naming this issue, 2022–2022
1 sentence

2022People v. R.C., 108 Ill. 2d 349, 355 (1985); see In re D.L.H., 2015 IL 117341, ¶¶ 56, 58, 81 (admission of involuntary statement to police is subject to harmless-error analysis).

11
In re D.L.H.green
ill · 2015 · cited in 1 Illinois opinions naming this issue, 2022–2022
1 sentence

2022People v. R.C., 108 Ill. 2d 349, 355 (1985); see In re D.L.H., 2015 IL 117341, ¶¶ 56, 58, 81 (admission of involuntary statement to police is subject to harmless-error analysis).

11
People v. Ortizgreen
ill · 2009 · cited in 1 Illinois opinions naming this issue, 2020–2020
1 sentence

2020People v. Ortiz, 235 Ill. 2d 319, 333 (2009).

11
Haley v. Ohiogreen
scotus · 1948 · cited in 1 Illinois opinions naming this issue, 2012–2012
1 sentence

2012App. 3d 728 , 736 (1997) (quoting Haley v. Ohio, 332 U.S. 596, 599, 601 (1948)). ¶ 83 Defendant’s principal argument regarding the motion to suppress is that he was interviewed by the police in violation of section 5-405 of the Juvenile Court Act of 1987 (705 ILCS 405/5-405 (West 2000)).

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 (29)

CaseCitedYears
People v. Bernard neutral
illappct · 2015
2 sentences

2015Close, 238 Ill. 2d at 504 . -3- 2015 IL App (2d) 140451 ¶ 12 Under the exclusionary rule, courts are precluded from admitting evidence that is gathered by the police in violation of the fourth amendment.

2015See, e.g., United States v. Dawdy, 46 F.3d 1427, 1430-31 (8th Cir. 1995) (suppression denied when resistance provided independent grounds for arrest); State v. Williams, 926 A.2d 340 (N.J. 2007) (interpreting New Jersey’s obstruction statute); Reynolds v. State, 634 S.E.2d 842, 845 (Ga. Ct. App. 2006) (act of fleeing was a separate crime). ¶ 57 Finally, the State contends that the evidence was nevertheless admissible under People v. Henderson, 2013 IL 114040 , a case that considered whether the abandonment of a gun during flight from officers broke the causal connection between an illegal stop

42015–2015
State v. Williams green
nj · 2007
2 sentences

2015See, e.g., United States v. Dawdy, 46 F.3d 1427, 1430-31 (8th Cir. 1995) (suppression denied when resistance provided independent grounds for arrest); State v. Williams, 926 A.2d 340 (N.J. 2007) (interpreting New Jersey’s obstruction statute); Reynolds v. State, 634 S.E.2d 842, 845 (Ga. Ct. App. 2006) (act of fleeing was a separate crime). ¶ 57 Finally, the State contends that the evidence was nevertheless admissible under People v. Henderson, 2013 IL 114040 , a case that considered whether the abandonment of a gun during flight from officers broke the causal connection between an illegal stop

2015See, e.g., United States v. Dawdy, 46 F.3d 1427, 1430-31 (8th Cir. 1995) (suppression denied when resistance provided independent grounds for arrest); State v. Williams, 926 A.2d 340 (N.J. 2007) (interpreting New Jersey’s obstruction statute); Reynolds v. State, 634 S.E.2d 842, 845 (Ga. Ct. App. 2006) (act of fleeing was a separate crime). ¶ 57 Finally, the State contends that the evidence was nevertheless admissible under People v. Henderson, 2013 IL 114040 , a case that considered whether the abandonment of a gun during flight from officers broke the causal connection between an illegal stop

32015–2015
People v. Henderson green
ill · 2013
2 sentences

2015See, e.g., United States v. Dawdy, 46 F.3d 1427, 1430-31 (8th Cir. 1995) (suppression denied when resistance provided independent grounds for arrest); State v. Williams, 926 A.2d 340 (N.J. 2007) (interpreting New Jersey’s obstruction statute); Reynolds v. State, 634 S.E.2d 842, 845 (Ga. Ct. App. 2006) (act of fleeing was a separate crime). ¶ 57 Finally, the State contends that the evidence was nevertheless admissible under People v. Henderson, 2013 IL 114040 , a case that considered whether the abandonment of a gun during flight from officers broke the causal connection between an illegal stop

2015See, e.g., United States v. Dawdy, 46 F.3d 1427, 1430-31 (8th Cir. 1995) (suppression denied when resistance provided independent grounds for arrest); State v. Williams, 926 A.2d 340 (N.J. 2007) (interpreting New Jersey’s obstruction statute); Reynolds v. State, 634 S.E.2d 842, 845 (Ga. Ct. App. 2006) (act of fleeing was a separate crime). ¶ 57 Finally, the State contends that the evidence was nevertheless admissible under People v. Henderson, 2013 IL 114040 , a case that considered whether the abandonment of a gun during flight from officers broke the causal connection between an illegal stop

32015–2015
Banks v. City of Chicago green
illappct · 1973
2 sentences

2019Id. at 545-46 . ¶ 39 The officer testified at trial that he was aware of a police rule that a police officer is considered to be on duty at all times and to respond immediately to any emergency.

2018Id. at 545-46 , 297 N.E.2d 343 . ¶ 39 The officer testified at trial that he was aware of a police rule that a police officer is considered to be on duty at all times and to respond immediately to any emergency.

22018–2019
Rodriguez v. United States green
scotus · 2015
2 sentences

2017Rodriguez, 575 U.S. at ____, 135 S. Ct. at 1614 .

2017Rodriguez, 575 U.S. at ___, 135 S. Ct. at 1614 .

22017–2017
People v. Close green
ill · 2010
2 sentences

2015Close, 238 Ill. 2d at 504 . ¶ 12 Under the exclusionary rule, courts are precluded from admitting evidence that is gathered by the police in violation of the fourth amendment.

2015Close, 238 Ill. 2d at 504 . -3- 2015 IL App (2d) 140451 ¶ 12 Under the exclusionary rule, courts are precluded from admitting evidence that is gathered by the police in violation of the fourth amendment.

22015–2015
Terry v. Ohio green
scotus · 1968
2 sentences

2003Ed. 2d 889 , 88 S. Ct. 1868 (1968))] as the police do not claim to have seen a crime committed or believe that the defendant was committing a crime upon their approach.

2003Ed. 2d 889 , 88 S. Ct. 1868 (1968))] as the police do not claim to have seen a crime committed or believe that the defendant was committing a crime upon their approach.

22003–2003
People v. Saunders green
illappct · 1992
1 sentence

2025Saunders, 235 Ill.

12025–2025
People v. Libberton green
illappct · 2004
1 sentence

2024In People v. Libberton, 346 Ill.

12024–2024
In re Marriage of Miklowicz neutral
illappct · 2022
1 sentence

2022Further, he contended, allowing respondent to recover fees in the criminal case would penalize him for making a good-faith effort to tell the police of a violation -2- 2022 IL App (2d) 210713 of the judgment.

12022–2022
People v. Washington green
illappct · 2006
1 sentence

2009Although none of these individual facts is dispositive (Washington, 363 Ill.

12009–2009
People v. Burnidge green
ill · 1997
2 sentences

2003The rationale for the inevitable-discovery doctrine is that "while `the prosecution is not to be put in a better position than it would have been in if no illegality had transpired,' the prosecution should not be put `in a worse position simply because of some earlier police error or misconduct.'" (Emphasis omitted.) People v. Burnidge, 178 Ill.2d 429, 437 , 227 Ill.Dec. 331 , 687 N.E.2d 813 (1997), quoting Nix, 467 U.S. at 443 , 104 S.Ct. at 2508 , 81 L.Ed.2d at 387 .

2003The rationale for the inevitable-discovery doctrine is that "while `the prosecution is not to be put in a better position than it would have been in if no illegality had transpired,' the prosecution should not be put `in a worse position simply because of some earlier police error or misconduct.'" (Emphasis omitted.) People v. Burnidge, 178 Ill.2d 429, 437 , 227 Ill.Dec. 331 , 687 N.E.2d 813 (1997), quoting Nix, 467 U.S. at 443 , 104 S.Ct. at 2508 , 81 L.Ed.2d at 387 .

12003–2003
In re Smith neutral
ilclaimsct · 1981
1 sentence

1996(In re Application of Smith (1981), 35 Ill.

11996–1996
United States v. Leon green
scotus · 1984
2 sentences

1993Burger directs “[the rule] cannot be expected, and should not be applied, to deter objectively reasonable law enforcement activity.” (Leon, 468 U.S. at 919 , 82 L.

1993Burger directs “[the rule] cannot be expected, and should not be applied, to deter objectively reasonable law enforcement activity.” (Leon, 468 U.S. at 919 , 82 L.

11993–1993
People v. Winsett green
illappct · 1991
2 sentences

1993"Therefore, Spruille's testimony, as the `fruit' of the actual violation of [the] defendant's fifth amendment privilege, should have been suppressed." ( Winsett, 222 Ill.App.3d at 67 , 164 Ill.Dec. 673 , 583 N.E.2d 589 .) However, no such problems exist in the case at bar.

1993“Therefore, Spruille’s testimony, as the ‘fruit’ of the actual violation of [the] defendant’s fifth amendment privilege, should have been suppressed.” (Winsett, 222 Ill.

11993–1993
People v. Richmond green
illappct · 1980
11992–1992
The People v. DePoy green
ill · 1968
11992–1992
Cupp v. Murphy green
scotus · 1973
11989–1989
People v. Hobson green
illappct · 1988
11988–1988
People v. Ellis green
cal · 1966
11984–1984
People v. Wolski green
illappct · 1980
11982–1982
People v. Nestrick neutral
illappct · 1977
11977–1977
People v. Taylor green
ill · 1972
11975–1975
United States v. Norman Laverne Wilcox green
ca4 · 1975
11975–1975
People v. Williams green
cal · 1971
11975–1975
Liddy v. United States green
scotus · 1975
11975–1975
Ellifrits v. United States Board of Parole green
scotus · 1975
11975–1975
Coolidge v. New Hampshire green
scotus · 1971
11974–1974
The CITY OF CHICAGO v. Jacobs green
ill · 1970
11971–1971

Statutes the citing opinions construe

IL § 720 ILCS 570/401 (9) IL § 725 ILCS 5/107-14 (7) IL § 725 ILCS 5/108-1.01 (7) IL § 720 ILCS 5/33A-2 (6) IL § 720 ILCS 570/402 (6) IL § 725 ILCS 5/122-1 (6) IL § 720 ILCS 5/24-1.1 (4) IL § 720 ILCS 5/24-1.2 (4) IL § 720 ILCS 550/4 (4) IL § 720 ILCS 550/5 (4) IL § 725 ILCS 5/114-12 (4) IL § 720 ILCS 5/7-7 (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.

Where else courts name it

NY 111 (1908–2025) IL 69 (1971–2025) MA 64 (1974–2024) CA 56 (1957–2022) PA 42 (1967–2025) TX 37 (1983–2026) NJ 25 (1964–2026) CT 20 (1966–2022) MI 18 (1969–2025) OR 17 (1960–2026) MN 16 (1983–2016) OH 16 (1978–2023) MD 16 (1971–2023) MO 14 (1968–2023) GA 12 (1970–2025) FL 11 (1995–2024) RI 10 (1968–2023) IN 10 (1981–2019) WA 9 (1967–2024) VA 9 (1980–2020) AZ 9 (1966–2023) DC 8 (1978–2015) NC 8 (1965–2001) IA 7 (1987–2016) AR 7 (1975–2010) AK 7 (1968–2018) ID 7 (1995–2020) TN 6 (1986–2025) WI 6 (1991–2022) DE 6 (1986–2020) AL 6 (1984–2024) CO 5 (1965–2008) LA 5 (1975–2005) KY 5 (1992–2013) HI 5 (2004–2017) WV 4 (1987–2015) ME 4 (1982–2015) KS 4 (1988–2013) UT 4 (1988–2016) NH 4 (1986–2015) MT 3 (1987–2015) VT 3 (1998–2010) ND 2 (1994–1996) SC 2 (1932–2020) NV 2 (1975–1989) NM 2 (2021–2022)

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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