gravity violation (Illinois) · Go Syfert
← Illinois issues

gravity violation in Illinois

67 Illinois opinions name it 2 courts 1978–2026 11 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 (13)

CaseFollowedCited
Buehler v. Whalengreen
ill · 1978 · cited in 22 Illinois opinions naming this issue, 1978–2026
2 sentences

2026See Buehler v. Whalen, 70 Ill. 2d 51, 67 (“Our discovery procedures are meaningless unless a violation entails a penalty proportionate to the gravity of the violation.”). ¶ 70 In short, an application of the Shimanovsky factors in this case demonstrates that the trial court properly exercised its discretion in concluding that the imposition of sanctions was warranted.

2010See Buehler v. Whalen, 70 Ill. 2d 51, 67 (1977) (“Our discovery procedures are meaningless unless a violation entails a penalty proportionate to the gravity of the violation.

822
In Re IFC Credit Corp.green
ca7 · 2011 · cited in 5 Illinois opinions naming this issue, 2012–2017
2 sentences

2017The actions taken by plaintiff were for the limited purpose of preserving her legal rights and those of the decedent’s next of kin and were not performed in the general prosecution of the lawsuit. ¶ 27 In addition, the Seventh Circuit Court of Appeals has determined that the sanction for violating the nullity rule “should be proportioned to the gravity of the violation’s consequences.” In re IFC Credit Corp., 663 F.3d 315, 321 (7th Cir. 2011).

2017The actions taken by plaintiff were for the limited purpose of preserving her legal rights and those of the decedent's next-of-kin, and were not performed in the general prosecution of the lawsuit. ¶ 27 In addition, the Seventh Circuit Court of Appeals has determined that the sanction for violating the nullity rule "should be proportioned to the gravity of the violation's consequences." In re IFC Credit Corp., 663 F. 3d 315, 321 (7th Cir. 2011).

45
People v. Durrgreen
ill · 2005 · cited in 2 Illinois opinions naming this issue, 2024–2026
2 sentences

2026Jan. 1, 1967)), under which “[p]lain errors or defects affecting substantial rights may be noticed although they were not brought to the attention of the trial court,” and we construe them “identically.” People v. Hartfield, 2022 IL 126729, ¶ 49 (citing Herron, 215 Ill. 2d at 175 ); see also People v. Sargent, 239 Ill. 2d 166, 189 (2010); People v. Durr, 215 Ill. 2d 283, 296-97 (2005). 25 No. 1-23-2093 ¶ 69 Under the plain error doctrine, a reviewing court may consider an unpreserved error when there was a clear and obvious error and either (1) the evidence was so closely balanced that the err

2024People v. Durr, 215 Ill. 2d 283, 296-97 (2005). ¶ 78 Under the plain error doctrine, we may consider an unpreserved error when there was a clear and obvious error and either (1) the evidence was so closely balanced that the error itself threatened to tip the scales of justice against the defendant, regardless of the gravity of the error, or (2) the error was so serious that it resulted in an unfair trial to the defendant and challenged the integrity of the judicial process, regardless of the closeness of the evidence.

22
People v. Nelsongreen
ill · 2009 · cited in 2 Illinois opinions naming this issue, 2018–2018
2 sentences

2018See Nelson , 235 Ill. 2d at 435 , 337 Ill.Dec. 479 , 922 N.E.2d 1056 . ¶ 38 While we reverse and remand for a new trial on the basis of the improper admission of the altered arrest photo, because we find the evidence was sufficient to convict defendant beyond a reasonable doubt, there are no double jeopardy concerns in remanding the case for a new trial.

2018See Nelson , 235 Ill. 2d at 435 , 337 Ill.Dec. 479 , 922 N.E.2d 1056 . ¶ 38 While we reverse and remand for a new trial on the basis of the improper admission of the altered arrest photo, because we find the evidence was sufficient to convict defendant beyond a reasonable doubt, there are no double jeopardy concerns in remanding the case for a new trial.

22
Gonzalez v. Nissan North America, Inc.green
illappct · 2006 · cited in 2 Illinois opinions naming this issue, 2015–2016
2 sentences

2016Gonzalez v. Nissan North America, Inc., 369 Ill.

2015Gonzalez v. Nissan North America, Inc., 369 Ill.

22
People v. Kiddgreen
ill · 1997 · cited in 2 Illinois opinions naming this issue, 2011–2011
2 sentences

2011People v. Kidd, 178 Ill.2d 92, 104-05 , 227 Ill.Dec. 463 , 687 N.E.2d 945, 952 (1997).

2011People v. Kidd, 178 Ill.2d 92, 104-05 , 227 Ill.Dec. 463 , 687 N.E.2d 945, 952 (1997).

22
United States v. Joseph Mark Andrewsgreen
ca7 · 1990 · cited in 2 Illinois opinions naming this issue, 2000–2000
2 sentences

2000See Andrews, 895 F.2d at 409 .

2000See Andrews, 895 F.2d at 409 .

22
People v. Hallgreen
ill · 2000 · cited in 3 Illinois opinions naming this issue, 2020–2021
2 sentences

2021Id. at 335 .

2021People v. Hall, 194 Ill. 2d 305, 335 (2000).

13
People v. Hartfieldgreen
ill · 2022 · cited in 2 Illinois opinions naming this issue, 2024–2026
2 sentences

2026Jan. 1, 1967)), under which “[p]lain errors or defects affecting substantial rights may be noticed although they were not brought to the attention of the trial court,” and we construe them “identically.” People v. Hartfield, 2022 IL 126729, ¶ 49 (citing Herron, 215 Ill. 2d at 175 ); see also People v. Sargent, 239 Ill. 2d 166, 189 (2010); People v. Durr, 215 Ill. 2d 283, 296-97 (2005). 25 No. 1-23-2093 ¶ 69 Under the plain error doctrine, a reviewing court may consider an unpreserved error when there was a clear and obvious error and either (1) the evidence was so closely balanced that the err

2024We reject the analogy as unsound because the speedy trial statute implements a constitutional right (People v. Hartfield, 2022 IL 126729, ¶ 32 ) and article 104 implements a civil statutory right and implementing a similar remedy for an untimely discharge hearing would only read into article 104 a provision neither included by the legislature (Grant, 2022 IL 126824, ¶ 25 ) nor required by the gravity of the violation. ¶ 53 Accordingly, for the foregoing reasons, we reject defendant’s contention that he is entitled to reversal of the trial court’s finding of not not guilty due to any untimeline

12
People v. Herrongreen
ill · 2005 · cited in 2 Illinois opinions naming this issue, 2016–2026
2 sentences

2026Jan. 1, 1967)), under which “[p]lain errors or defects affecting substantial rights may be noticed although they were not brought to the attention of the trial court,” and we construe them “identically.” People v. Hartfield, 2022 IL 126729, ¶ 49 (citing Herron, 215 Ill. 2d at 175 ); see also People v. Sargent, 239 Ill. 2d 166, 189 (2010); People v. Durr, 215 Ill. 2d 283, 296-97 (2005). 25 No. 1-23-2093 ¶ 69 Under the plain error doctrine, a reviewing court may consider an unpreserved error when there was a clear and obvious error and either (1) the evidence was so closely balanced that the err

2016For the reasons that follow, I find that the latter formulation is the more logical recitation. ¶ 35 The necessity of my conclusion is illustrated by the oft-quoted but contradictory case of Herron, 215 Ill. 2d at 178, 187 .

12
People v. Sargentgreen
ill · 2010 · cited in 1 Illinois opinions naming this issue, 2026–2026
1 sentence

2026Jan. 1, 1967)), under which “[p]lain errors or defects affecting substantial rights may be noticed although they were not brought to the attention of the trial court,” and we construe them “identically.” People v. Hartfield, 2022 IL 126729, ¶ 49 (citing Herron, 215 Ill. 2d at 175 ); see also People v. Sargent, 239 Ill. 2d 166, 189 (2010); People v. Durr, 215 Ill. 2d 283, 296-97 (2005). 25 No. 1-23-2093 ¶ 69 Under the plain error doctrine, a reviewing court may consider an unpreserved error when there was a clear and obvious error and either (1) the evidence was so closely balanced that the err

11
In Re Marriage of Laigreen
illappct · 1993 · cited in 1 Illinois opinions naming this issue, 2023–2023
1 sentence

2023In fact, the record is devoid of any request for the missing information by Mr. Harris prior to requesting sanctions. ¶ 66 “Sanctions must be proportionate to the gravity of the violation.” In re Marriage of Lai, 253 Ill.

11
People v. Williamsgreen
ill · 1982 · cited in 1 Illinois opinions naming this issue, 2012–2012
2 sentences

2012I, § 8. *** The gravity of a waiver [of counsel] requires a trial court to fully inform a defendant of both the nature of the right being abandoned and the consequences of the decision.” People v. Black, 2011 IL App (5th) 080089, ¶ 11 , 953 N.E.2d 958 . ¶ 40 In reaching this decision, we have considered what the Supreme Court of Illinois wrote 30 years ago in People v. Williams, 92 Ill. 2d 109, 118 , 440 N.E.2d 843, 847 (1982): “[W]here a defendant who is financially able to engage counsel has been instructed to do so within a certain and reasonable time, but he fails to do so and does not sho

2012I, § 8. *** The gravity of a waiver [of counsel] requires a trial court to fully inform a defendant of both the nature of the right being abandoned and the consequences of the decision.” People v. Black, 2011 IL App (5th) 080089, ¶ 11 , 953 N.E.2d 958 . ¶ 40 In reaching this decision, we have considered what the Supreme Court of Illinois wrote 30 years ago in People v. Williams, 92 Ill. 2d 109, 118 , 440 N.E.2d 843, 847 (1982): “[W]here a defendant who is financially able to engage counsel has been instructed to do so within a certain and reasonable time, but he fails to do so and does not sho

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 (23)

CaseCitedYears
People v. Sebby green
ill · 2017
2 sentences

2026People v. Sebby, 2017 IL 119445 , ¶ 48.

2024People v. Sebby, 2017 IL 119445, ¶ 48 .

92019–2026
People v. Black green
illappct · 2011
2 sentences

2015“The gravity of a waiver requires a trial court to fully inform a defendant of both the nature of the right being abandoned and the consequences of the decision.” Id.

2015“The gravity of a waiver requires a trial court to fully inform a defendant of both the nature of the right being abandoned and the consequences of the decision.” Id.

42012–2015
Spiller v. Continental Tube Co. green
ill · 1983
2 sentences

1993(Spiller v. Continental Tube Co. (1983), 95 Ill. 2d 423, 430-31 , 447 N.E.2d 834 .) Here, default, the harshest sanction available to the court, was the first sanction entered.

1993(Spiller v. Continental Tube Co. (1983), 95 Ill. 2d 423, 430-31 , 447 N.E.2d 834 .) Here, default, the harshest sanction available to the court, was the first sanction entered.

31986–1993
People v. Davis green
ill · 1991
2 sentences

2019Even though the defendant forfeited this issue by failing to raise it in his motion to withdraw his guilty plea, the supreme court stated, “Due to the gravity of the error, and in the interests of justice, we believe defendant’s failure to raise the issue in his motion does not waive it on appeal.” Davis, 145 Ill. 2d at 251 , 582 N.E.2d at 719 .

2019Even though the defendant forfeited this issue by failing to raise it in his motion to withdraw his guilty plea, the supreme court stated, “Due to the gravity of the error, and in the interests of justice, we believe defendant’s failure to raise the issue in his motion does not waive it on appeal.” Davis, 145 Ill. 2d at 251 , 582 N.E.2d at 719 .

22019–2020
Servbest Foods, Inc. v. Emessee Industries, Inc. green
illappct · 1980
2 sentences

1987App. 3d 662, 680 , 403 N.E.2d 1, 15 .) Sanctions must be proportionate to the gravity of the violation.

1986App. 3d 662, 680 , 403 N.E.2d 1 .) Sanctions must be proportionate to the gravity of the violation.

21986–1987
United States v. Gonzalez-Lopez green
scotus · 2006
1 sentence

2025Id.

12025–2025
People v. Grant green
ill · 2022
1 sentence

2024We reject the analogy as unsound because the speedy trial statute implements a constitutional right (People v. Hartfield, 2022 IL 126729, ¶ 32 ) and article 104 implements a civil statutory right and implementing a similar remedy for an untimely discharge hearing would only read into article 104 a provision neither included by the legislature (Grant, 2022 IL 126824, ¶ 25 ) nor required by the gravity of the violation. ¶ 53 Accordingly, for the foregoing reasons, we reject defendant’s contention that he is entitled to reversal of the trial court’s finding of not not guilty due to any untimeline

12024–2024
People v. J.F. green
illappct · 2024
1 sentence

2024Judicial Notice of Fitness Evaluation and Status Update Reports - 20 - 2024 IL App (2d) 230259 ¶ 55 Defendant argues next that the trial court abused its discretion in failing to take judicial notice of Oliverio’s fitness evaluation and the status reports provided by the Ecker Center in considering whether defendant acted knowingly when he rubbed G.F.’s breasts.

12024–2024
People v. Pitsonbarger green
ill · 2002
1 sentence

2024Id. at 459 .

12024–2024
People v. Black green
illappct · 2011
1 sentence

2012I, § 8. *** The gravity of a waiver [of counsel] requires a trial court to fully inform a defendant of both the nature of the right being abandoned and the consequences of the decision.” People v. Black, 2011 IL App (5th) 080089, ¶ 11 , 953 N.E.2d 958 . ¶ 40 In reaching this decision, we have considered what the Supreme Court of Illinois wrote 30 years ago in People v. Williams, 92 Ill. 2d 109, 118 , 440 N.E.2d 843, 847 (1982): “[W]here a defendant who is financially able to engage counsel has been instructed to do so within a certain and reasonable time, but he fails to do so and does not sho

12012–2012
Ford Motor Credit Co. v. Sperry green
ill · 2005
1 sentence

2012Applebaum, 231 Ill. 2d at 439 (citing Sperry, 214 Ill. 2d at 382 ). ¶ 31 We hold there is no automatic nullity rule.

12012–2012
Applebaum v. RUSH UNIVERSITY MEDICAL CENTER green
ill · 2008
1 sentence

2012Applebaum, 231 Ill. 2d at 439 (citing Sperry, 214 Ill. 2d at 382 ). ¶ 31 We hold there is no automatic nullity rule.

12012–2012
Boettcher v. Fournie Farms, Inc. green
illappct · 1993
1 sentence

1995(Boettcher v. Fournie Farms, Inc. (1993), 243 Ill.

11995–1995
Ostendorf v. International Harvester Co. green
ill · 1982
2 sentences

1993In Buehler v. Whalen (1977), 70 Ill. 2d 51 , 374 N.E.2d 460 , our supreme court instructed us that half-truths are equivalent to outright lies and “fractional disclosure” is not the disclosure contemplated by our discovery rules. ( 70 Ill. 2d at 67-68 , 374 N.E.2d at 467-68 .) “[Hjalf-truths *** have the effect of affirmative concealment, since they imply that there is no information or evidence to be sought.” Ostendorf v. International Harvester Co. (1982), 89 Ill. 2d 273, 282 , 433 N.E.2d 253, 257 . “[0]ur discovery procedures are meaningless unless a violation entails a penalty proportionat

1993In Buehler v. Whalen (1977), 70 Ill. 2d 51 , 374 N.E.2d 460 , our supreme court instructed us that half-truths are equivalent to outright lies and “fractional disclosure” is not the disclosure contemplated by our discovery rules. ( 70 Ill. 2d at 67-68 , 374 N.E.2d at 467-68 .) “[Hjalf-truths *** have the effect of affirmative concealment, since they imply that there is no information or evidence to be sought.” Ostendorf v. International Harvester Co. (1982), 89 Ill. 2d 273, 282 , 433 N.E.2d 253, 257 . “[0]ur discovery procedures are meaningless unless a violation entails a penalty proportionat

11993–1993
Leeson v. State Farm Mutual Automobile Insurance green
illappct · 1989
1 sentence

1992App. 3d 359, 368 , 546 N.E.2d 782, 788 .) “Pursuant to Supreme Court Rule 220 (107 Ill. 2d R. 220), sanctions imposed for violations of discovery rules must be proportionate to the gravity of the violation. [Citation.] The purpose of a sanction pursuant to Rule 220 is not to punish [citation], but to insure fair discovery and a trial on the merits [citation].

11992–1992
Caruso v. Pine Manor Nursing Center neutral
illappct · 1989
2 sentences

1992A trial court’s exercise of its broad discretion in imposing sanctions for discovery violations will not be disturbed absent a clear abuse.” Caruso v. Pine Manor Nursing Center (1989), 182 Ill.

1992A trial court's exercise of its broad discretion in imposing sanctions for discovery violations will not be disturbed absent a clear abuse." Caruso v. Pine Manor Nursing Center (1989), 182 Ill.App.3d 879 , 131 Ill.Dec. 347 , 538 N.E.2d 722 .

11992–1992
Slatten v. City of Chicago green
illappct · 1973
1 sentence

1991App. 3d 808 , 299 N.E.2d 442 .) “Our discovery procedures are meaningless unless a violation entails a penalty proportionate to the gravity of the violation.

11991–1991
People v. Reddick green
ill · 1988
11990–1990
Peoples Gas, Light & Coke Co. v. Chicago Black Improvement Ass'n neutral
illappct · 1986
11989–1989
In Re Estate of Soderholm green
illappct · 1984
11987–1987
Barnes v. Black & Decker Manufacturing Co. neutral
illappct · 1985
11986–1986
Plost v. Louis A. Weiss Memorial Hospital green
illappct · 1978
11986–1986
People v. Jones green
illappct · 1972
11982–1982

Statutes the citing opinions construe

IL § 720 ILCS 5/9-1 (6) IL § 735 ILCS 5/2-619 (4) IL § 5 ILCS 70/1.11 (3) IL § 720 ILCS 5/12-30 (3) IL § 735 ILCS 5/2-622 (3) IL § 750 ILCS 60/220 (3) IL § 750 ILCS 60/222.10 (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

OR 500 (1991–2026) IL 67 (1978–2026) FL 18 (1993–2026) PA 14 (1977–2024) WA 12 (2012–2026) NJ 8 (1953–2020) DC 8 (1985–2024) NY 8 (1962–2025) CT 7 (1992–2015) NC 6 (2019–2025) TX 6 (1975–2019) CA 4 (1955–2023) LA 4 (1998–2020) WY 3 (1986–2007) VA 3 (2022–2024) KY 3 (1957–2024) WV 2 (1974–2018) MN 2 (2004–2006) MI 2 (1952–1974) NV 2 (2022–2023) NH 2 (1986–1994) TN 2 (2001–2011)

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.

← Caselaw search · G Cite Topics · Brief Check