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.
| Case | Followed | Cited |
|---|---|---|
Nix v. Williamsgreen2 sentences2025And 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 | 21 | 25 |
People v. Sutherlandgreen2 sentences2025And 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. | 18 | 20 |
People v. Edwardsgreen2 sentences2025The 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. | 8 | 9 |
United States v. Eugene L. Dawdygreen2 sentences2015See, 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 | 3 | 3 |
Reynolds v. Stategreen2 sentences2015See, 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 | 3 | 3 |
People v. Gantergreen2 sentences2014People v. Ganter, 56 Ill. 2013People v. Ganter, 56 Ill. | 3 | 3 |
People v. Mitchellgreen2 sentences2004Under 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. | 3 | 3 |
Provena Covenant Medical Center v. Department of Revenuegreen2 sentences2014See Provena Covenant Medical Center, 236 Ill. 2d at 386-87 . 2014See Provena Covenant Medical Center, 236 Ill. 2d at 368-87 . | 2 | 2 |
State v. Andersongreen2 sentences2005See, 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). | 2 | 2 |
People v. Hundleygreen1 sentence2024An 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). | 1 | 1 |
Florida v. Wellsgreen1 sentence2024An 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). | 1 | 1 |
People v. R.C.green1 sentence2022People 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). | 1 | 1 |
In re D.L.H.green1 sentence2022People 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). | 1 | 1 |
People v. Ortizgreen1 sentence2020People v. Ortiz, 235 Ill. 2d 319, 333 (2009). | 1 | 1 |
Haley v. Ohiogreen1 sentence2012App. 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)). | 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. Bernard
neutral
2 sentences2015Close, 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 | 4 | 2015–2015 |
State v. Williams
green
2 sentences2015See, 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 | 3 | 2015–2015 |
People v. Henderson
green
2 sentences2015See, 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 | 3 | 2015–2015 |
Banks v. City of Chicago
green
2 sentences2019Id. 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. | 2 | 2018–2019 |
Rodriguez v. United States
green
2 sentences2017Rodriguez, 575 U.S. at ____, 135 S. Ct. at 1614 . 2017Rodriguez, 575 U.S. at ___, 135 S. Ct. at 1614 . | 2 | 2017–2017 |
People v. Close
green
2 sentences2015Close, 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. | 2 | 2015–2015 |
Terry v. Ohio
green
2 sentences2003Ed. 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. | 2 | 2003–2003 |
People v. Saunders
green
1 sentence2025Saunders, 235 Ill. | 1 | 2025–2025 |
People v. Libberton
green
1 sentence2024In People v. Libberton, 346 Ill. | 1 | 2024–2024 |
In re Marriage of Miklowicz
neutral
1 sentence2022Further, 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. | 1 | 2022–2022 |
People v. Washington
green
1 sentence2009Although none of these individual facts is dispositive (Washington, 363 Ill. | 1 | 2009–2009 |
People v. Burnidge
green
2 sentences2003The 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 . | 1 | 2003–2003 |
In re Smith
neutral
1 sentence1996(In re Application of Smith (1981), 35 Ill. | 1 | 1996–1996 |
United States v. Leon
green
2 sentences1993Burger 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. | 1 | 1993–1993 |
People v. Winsett
green
2 sentences1993"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. | 1 | 1993–1993 |
| People v. Richmond green | 1 | 1992–1992 |
| The People v. DePoy green | 1 | 1992–1992 |
| Cupp v. Murphy green | 1 | 1989–1989 |
| People v. Hobson green | 1 | 1988–1988 |
| People v. Ellis green | 1 | 1984–1984 |
| People v. Wolski green | 1 | 1982–1982 |
| People v. Nestrick neutral | 1 | 1977–1977 |
| People v. Taylor green | 1 | 1975–1975 |
| United States v. Norman Laverne Wilcox green | 1 | 1975–1975 |
| People v. Williams green | 1 | 1975–1975 |
| Liddy v. United States green | 1 | 1975–1975 |
| Ellifrits v. United States Board of Parole green | 1 | 1975–1975 |
| Coolidge v. New Hampshire green | 1 | 1974–1974 |
| The CITY OF CHICAGO v. Jacobs green | 1 | 1971–1971 |
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.