variance claim (Illinois) · Go Syfert
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variance claim in Illinois

9 Illinois opinions name it 2 courts 1906–2022 1 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 (3)

CaseFollowedCited
People v. Maggettegreen
ill · 2001 · cited in 2 Illinois opinions naming this issue, 2011–2011
2 sentences

2011For a variance between the charging instrument and the proof at trial to be fatal, the difference "must be material and be of such character as may mislead the defendant in making his or her defense, or expose the defendant to double jeopardy." People v. Maggette, 195 Ill.2d 336, 351 , 254 Ill.Dec. 299 , 747 N.E.2d 339 (2001).

2011For a variance between the charging instrument and the proof at trial to be fatal, the difference "must be material and be of such character as may mislead the defendant in making his or her defense, or expose the defendant to double jeopardy." People v. Maggette, 195 Ill.2d 336, 351 , 254 Ill.Dec. 299 , 747 N.E.2d 339 (2001).

12
People v. Rothermelgreen
ill · 1982 · cited in 2 Illinois opinions naming this issue, 2011–2011
2 sentences

2011"Struck" About the Body ¶ 66 Defendant argues that the State failed to meet its burden of proving every element as charged in the indictment because it did not introduce evidence that defendant "struck" Lee "about the body." The State argues that defendant's claim is *1260 really a variance claim, rather than a "failure of proof" argument, and we agree. ¶ 67 The State "must prove the essential elements of the charging instrument." People v. Rothermel, 88 Ill.2d 541, 544 , 59 Ill.Dec. 93 , 431 N.E.2d 378 (1982).

2011"Struck" About the Body ¶ 66 Defendant argues that the State failed to meet its burden of proving every element as charged in the indictment because it did not introduce evidence that defendant "struck" Lee "about the body." The State argues that defendant's claim is *1260 really a variance claim, rather than a "failure of proof" argument, and we agree. ¶ 67 The State "must prove the essential elements of the charging instrument." People v. Rothermel, 88 Ill.2d 541, 544 , 59 Ill.Dec. 93 , 431 N.E.2d 378 (1982).

12
Environmental Protection Agency v. Pollution Control Boardgreen
ill · 1981 · cited in 1 Illinois opinions naming this issue, 1983–1983
1 sentence

1983See also Environmental Protection Agency v. Pollution Control Board (1981), 86 Ill.2d 390, 400 ; Willowbrook Development Corp. v. Pollution Control Board (1981), 92 Ill.

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 (11)

CaseCitedYears
People v. Espinoza green
ill · 2015
1 sentence

2022People v. Espinoza, 2015 IL 118218, ¶ 15 ; People v. Stephenson, 2016 IL App (1st) 142031 , ¶ 16.

12022–2022
People v. Stephenson green
illappct · 2016
1 sentence

2022People v. Espinoza, 2015 IL 118218, ¶ 15 ; People v. Stephenson, 2016 IL App (1st) 142031 , ¶ 16.

12022–2022
Citizens Utilities Co. v. Pollution Control Board neutral
illappct · 1985
1 sentence

1987(Citizens Utilities Co. v. Pollution Control Board (1985), 134 Ill.

11987–1987
Willowbrook Development Corp. v. Pollution Control Board green
illappct · 1981
1 sentence

1983See also Environmental Protection Agency v. Pollution Control Board (1981), 86 Ill.2d 390, 400 ; Willowbrook Development Corp. v. Pollution Control Board (1981), 92 Ill.

11983–1983
Monsanto Co. v. Pollution Control Board green
ill · 1977
2 sentences

1983(Monsanto Co. v. Pollution Control Board (1977), 67 Ill. 2d 276, 289-90 .

1983Our supreme court has held that the decision whether to grant a variance from an environmental regulation is quasi-adjudicatory, although the imposition of conditions on the variance is rule making. ( Monsanto Co. v. Pollution Control Board (1977), 67 Ill.2d 276, 289-90 .

11983–1983
Bluett v. County of Cook green
illappct · 1958
1 sentence

1982(Bluett v. County of Cook (1958), 19 Ill.

11982–1982
Molex, Inc. v. Pollution Control Board green
illappct · 1973
1 sentence

1973We believe that the legislature intentionally omitted the provisions of section 33(b) from applying to a variance hearing under section 37; and, therefore, under a strict interpretation of the Act the Board does not have the power to impose a penalty as a condition to granting a variance under the Environmental Protection Act.” 293 N.E.2d at 732 .

11973–1973
City of Mattoon v. Environmental Protection Agency neutral
illappct · 1973
2 sentences

1973Citizens Utilities was also followed in City of Mattoon v. Environmental Protection Agency, 11 Ill.App.3d 259 , 296 N.E.2d 383 (4th Dist, 1973), which case reached the same holding as Citizens Utilities and Molex.

1973Citizens Utilities was also followed in City of Mattoon v. Environmental Protection Agency, 11 Ill.App.3d 259 , 296 N.E.2d 383 (4th Dist, 1973), which case reached the same holding as Citizens Utilities and Molex.

11973–1973
Hall v. Jones green
ill · 1863
1 sentence

1933In Hall v. Jones, 32 Ill. 38 , where the note upon which judgment was confessed was for the principal sum of $2,000 and the declaration averred it to be for $1,000, the court held the variance was such an error as was released by the cognovit.

11933–1933
Hall v. Hamilton neutral
ill · 1874
1 sentence

1933Hall v. Hamilton, supra, was a case where the declaration claimed damages to the amount of $614; the cognovit confessed $634 and judgment was entered for the latter amount; also, the cognovit was entitled in the circuit court of Cook county, while it was filed in the superior court of such county.

11933–1933
Guedel v. People neutral
ill · 1867
1 sentence

1906In Guedel v. People, 43 Ill. 226 , in discussing the doctrine of variance, this court said (p. 229) : “It has its origin in that tenderness of the law for human life which requires that a prisoner on trial for murder shall be fully informed by the indictment of the precise nature of the charge he is called to meet.” Further along, on the same page, it is said: “The mode in which the killing was accomplished is an essential part of the indictment, and if two indictménts allege modes of killing so substantially unlike that the evidence necessary to sustain the one would not be admissible under t

11906–1906

Where else courts name it

TX 48 (1881–2023) PA 36 (1928–2026) RI 31 (1965–2026) NY 16 (1929–2024) TN 15 (1982–2022) AL 13 (1881–2016) CT 13 (1955–2022) CA 12 (1944–2021) MD 11 (1967–2025) NJ 10 (1880–2008) IL 9 (1906–2022) ME 7 (1982–2016) FL 6 (1962–1996) IA 6 (1933–2026) OR 6 (1979–2026) NH 6 (2004–2015) UT 5 (1987–2023) DC 5 (1979–2023) ID 5 (2018–2025) NC 5 (1981–2009) MA 4 (1985–2010) IN 4 (1979–1993) SC 3 (1967–2014) OK 3 (1915–1973) LA 3 (1967–1971) HI 2 (1998–2015) NM 2 (2011–2021) OH 2 (1946–2011) AZ 2 (1936–2017) GA 2 (1934–1978) MO 2 (1997–2015) KY 2 (1959–1974) AK 2 (2008–2020) MS 2 (1966–1975) MI 2 (1950–1962)

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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