64 Illinois opinions name it 2 courts 1977–2024 8 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. Sargentgreen2 sentences2023Correspondingly, where a defendant confesses to multiple offenses, the corroboration rule requires that there be independent evidence tending to show that defendant committed each of the offenses for which he was convicted.” People v. Sargent, 239 Ill. 2d 166, 185 (2010). ¶ 16 We find the decision in People v. McKown, 2021 IL App (4th) 190660 , instructive. 2021On appeal, the defendant challenged several of his convictions as they related to M.G. on the basis “that the only evidence adduced by the State on [the challenged] counts consisted of his own, uncorroborated confession.” Id. at 182 . ¶ 40 The supreme court agreed, finding defendant was properly convicted of predatory criminal sexual assault of J.W. and one count of predatory criminal sexual assault of M.G., but his remaining convictions could not “be sustained under the corroboration rule,” i.e., the corpus delicti rule. | 4 | 11 |
People v. Salinasgreen2 sentences2011The State argues that instead of applying the corroboration rule from Dalton , we should apply the rule stated in People v. Salinas, 347 Ill.App.3d 867, 881 , 283 Ill. 2011The State argues that instead of applying the corroboration rule from Dalton , we should apply the rule stated in People v. Salinas, 347 Ill.App.3d 867, 881 , 283 Ill. | 4 | 4 |
People v. Romerogreen2 sentences2019See People v. Romero, 2015 IL App (1st) 140205, ¶ 27 (“If a single claim in a multiple-claim postconviction petition survives the summary dismissal stage ***, then the entire petition must be docketed for second-stage proceedings[,] regardless of the merits of the remaining claims in the petition.”); People v. White, 2014 IL App (1st) 130007, ¶ 33 (“We have no need to address any of the other claims in the petition because partial summary dismissals are not permitted during the first stage of a postconviction proceeding.”). ¶ 26 C. 2018See People v. Romero, 2015 IL App (1st) 140205, ¶ 27 (“If a single claim in a multiple-claim postconviction petition survives the summary dismissal stage ***, then the entire petition must be docketed for second-stage proceedings[,] regardless of the merits of the remaining claims in the petition.”); People v. White, 2014 IL App (1st) 130007, ¶ 33 (“We have no need to address any of the other claims in the petition because partial summary dismissals are not permitted during the first stage of a postconviction proceeding.”). ¶ 26 C. | 3 | 3 |
People v. Boundsgreen2 sentences2013Thus, when a confession involves more than one offense, “the corroboration rule requires that there be independent evidence tending to show that defendant committed each of the offenses for which he was convicted.” Sargent, 239 Ill. 2d at 185 (citing People v. Bounds, 171 Ill. 2d 1, 42-46 (1995)). 2013When considering whether evidence that the defendant had placed his finger in the child’s anus could corroborate his confession to fondling the child’s penis, the court relied on Bounds for the rule that, “where a defendant confesses to multiple offenses, the corroboration rule requires that there be independent evidence tending to show that defendant committed each of the offenses for which he was convicted.” Sargent, 239 Ill. 2d at 185 (citing Bounds, 171 Ill. 2d at 42-46 ). | 3 | 3 |
People v. Furbygreen2 sentences2009The corroboration requirement “reflects a longstanding mistrust of extrajudicial confessions” (Furby, 138 Ill. 2d at 447 ), and it “stems from an attempt to assure the truthfulness of the confession and recognizes that the reliability of a confession ‘may be suspect if it is extracted from one who is under the pressure of a police investigation — whose words may reflect the strain and confusion attending his predicament rather than a clear reflection of his past.’ ” Willingham, 89 Ill. 2d at 359 , quoting Smith v. United States, 348 U.S. 147, 153 , 99 L. 2009The corroboration requirement "reflects a long-standing mistrust of extrajudicial confessions" ( Furby, 138 Ill.2d at 447 , 150 Ill.Dec. 534 , 563 N.E.2d 421 ), and it "stems from an attempt to assure the truthfulness of the confession and recognizes that the reliability of a confession `may be suspect if it is extracted from one who is under the pressure of a police investigation whose words may reflect the strain and confusion attending his predicament rather than a clear reflection of his past.'" Willingham, 89 Ill.2d at 359 , 59 Ill.Dec. 917 , 432 N.E.2d 861 , quoting Smith v. United Sta | 2 | 6 |
Smith v. United Statesgreen2 sentences2009The corroboration requirement “reflects a longstanding mistrust of extrajudicial confessions” (Furby, 138 Ill. 2d at 447 ), and it “stems from an attempt to assure the truthfulness of the confession and recognizes that the reliability of a confession ‘may be suspect if it is extracted from one who is under the pressure of a police investigation — whose words may reflect the strain and confusion attending his predicament rather than a clear reflection of his past.’ ” Willingham, 89 Ill. 2d at 359 , quoting Smith v. United States, 348 U.S. 147, 153 , 99 L. 2009The corroboration requirement “reflects a longstanding mistrust of extrajudicial confessions” (Furby, 138 Ill. 2d at 447 ), and it “stems from an attempt to assure the truthfulness of the confession and recognizes that the reliability of a confession ‘may be suspect if it is extracted from one who is under the pressure of a police investigation — whose words may reflect the strain and confusion attending his predicament rather than a clear reflection of his past.’ ” Willingham, 89 Ill. 2d at 359 , quoting Smith v. United States, 348 U.S. 147, 153 , 99 L. | 2 | 6 |
In Re APgreen2 sentences2020W., 2014 IL App (3d) 130526 , ¶ 63 (citing In re A.P., 179 Ill. 2d 184, 199 (1997)). ¶ 33 In the case at bar, A.S.’s statement to Richmond was corroborated by respondent’s medical records, which show that on September 10, 2018, 2 respondent was brought to the emergency room of Jackson Park Hospital by the Chicago Police Department, accompanied by her mother, for “violent and aggressive behavior at home and medication non-complian[ce].” The progress notes from that visit state, in relevant part, that respondent was brought to the emergency room “because she was physically aggressive toward her 2020W., 2014 IL App (3d) 130526 , ¶ 63 (citing In re A.P., 179 Ill. 2d 184, 199 (1997)). ¶ 33 In the case at bar, A.S.’ statement to Richmond was corroborated by respondent’s medical records, which show that on September 10, 2018, 2 respondent was brought to the emergency room of Jackson Park Hospital by the Chicago Police Department, accompanied by her mother, 2 September 10, 2018, was actually the Monday before September 16, not the Tuesday. | 2 | 4 |
People v. Whitegreen2 sentences2019See People v. Romero, 2015 IL App (1st) 140205, ¶ 27 (“If a single claim in a multiple-claim postconviction petition survives the summary dismissal stage ***, then the entire petition must be docketed for second-stage proceedings[,] regardless of the merits of the remaining claims in the petition.”); People v. White, 2014 IL App (1st) 130007, ¶ 33 (“We have no need to address any of the other claims in the petition because partial summary dismissals are not permitted during the first stage of a postconviction proceeding.”). ¶ 26 C. 2018See People v. Romero, 2015 IL App (1st) 140205, ¶ 27 (“If a single claim in a multiple-claim postconviction petition survives the summary dismissal stage ***, then the entire petition must be docketed for second-stage proceedings[,] regardless of the merits of the remaining claims in the petition.”); People v. White, 2014 IL App (1st) 130007, ¶ 33 (“We have no need to address any of the other claims in the petition because partial summary dismissals are not permitted during the first stage of a postconviction proceeding.”). ¶ 26 C. | 2 | 3 |
People v. Shafergreen2 sentences2012See People v. Shafer, 372 Ill.App.3d 1044, 1052-53 , 311 Ill.Dec. 359 , 868 N.E.2d 359 (2007). 2012See People v. Shafer, 372 Ill.App.3d 1044, 1052-53 , 311 Ill.Dec. 359 , 868 N.E.2d 359 (2007). | 2 | 3 |
People v. Wardgreen2 sentences2014App. 3d 750, 761-62 (1993) (discussing a similar corroboration requirement under section 115-10 of the Code of Criminal Procedure of 1963); People v. Ward, 207 Ill. 2014App. 3d 750, 761-62 (1993) (discussing a similar corroboration requirement under section 115-10 of the Code of Criminal Procedure of 1963); People v. Ward, 207 Ill. | 2 | 2 |
People v. Richmondgreen2 sentences2011See People v. Richmond, 341 Ill.App.3d 39, 46 [ 274 Ill.Dec. 721 , 791 N.E.2d 1132 ] (2003) (corroboration rule applied to overturn conviction and sentence involving unlawful penis-to-vagina contact, notwithstanding defendant's confession, where corroborating evidence substantiated only penis-to-anus contact). 2011See People v. Richmond, 341 Ill.App.3d 39, 46 [ 274 Ill.Dec. 721 , 791 N.E.2d 1132 ] (2003) (corroboration rule applied to overturn conviction and sentence involving unlawful penis-to-vagina contact, notwithstanding defendant's confession, where corroborating evidence substantiated only penis-to-anus contact). | 2 | 2 |
People v. Daltongreen2 sentences2013We noted that the rationale behind the historical mistrust of extrajudicial confessions underlying the corroboration rule would not “be served by applying it in [those] circumstances,” because the element of age was “not subject to the same infirmities when admitted to by a defendant as are more subjective admissions.” Dalton, 91 Ill. 2d at 29 . 2011Our supreme court later overruled Wistrand , and modified the corroboration rule, in People v. Dalton, 91 Ill.2d 22 , 61 Ill.Dec. 530 , 434 N.E.2d 1127 (1982). | 1 | 10 |
People v. Lambertgreen2 sentences1987(People v. Lambert (1984), 104 Ill. 2d 375 .) “The corroboration requirement stems from an attempt to assure the truthfulness of the confession and recognizes that the reliability of a confession ‘may be suspect’ ” either because of coercion, confusion or reason to fabricate. 1987It is axiomatic that a conviction may not stand on an accused's confession alone without evidence of the corpus delicti. ( People v. Lambert (1984), 104 Ill.2d 375 .) "The corroboration requirement stems from an attempt to assure the truthfulness of the confession and recognizes *472 that the reliability of a confession `may be suspect'" either because of coercion, confusion or reason to fabricate. ( People v. Willingham (1982), 89 Ill.2d 352, 359 , quoting Smith v. United States (1954), 348 U.S. 147, 153 , 99 L.Ed. 192, 199 , 75 S.Ct. 194, 197 .) Since uncorroborated statements cannot support | 1 | 6 |
People v. Laragreen2 sentences2022Id. ¶ 46 The corroboration requirement stems from a historical mistrust of extrajudicial confessions. 2019See Lara, 2012 IL 112370, ¶ 87 (Thomas, J., specially concurring). | 1 | 5 |
People v. Laragreen1 sentence2013Essentially, this would make the confession corroboration for the victim’s testimony, thereby requiring the State to prove the crime twice over ***.” 408 Ill. | 1 | 1 |
People v. Smulikgreen2 sentences2012The officer’s “personal observations corroborated only noninculpatory aspects of the tip–that a vehicle fitting a certain description would be found at a particular location.” Smulik, 2012 IL App (2d) 110110, ¶ 9 . ¶ 34 Further, the Second District recognized that the corroboration standard has been relaxed in the case of drunk drivers because of the threat that such drivers pose to public safety. 2012Smulik, 2012 IL App (2d) 110110, ¶ 11 (citing Shafer, 372 Ill. | 1 | 1 |
| In Re DAgreen | 1 | 1 |
| People v. Browngreen | 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. Willingham
green
2 sentences2009The corroboration requirement “reflects a longstanding mistrust of extrajudicial confessions” (Furby, 138 Ill. 2d at 447 ), and it “stems from an attempt to assure the truthfulness of the confession and recognizes that the reliability of a confession ‘may be suspect if it is extracted from one who is under the pressure of a police investigation — whose words may reflect the strain and confusion attending his predicament rather than a clear reflection of his past.’ ” Willingham, 89 Ill. 2d at 359 , quoting Smith v. United States, 348 U.S. 147, 153 , 99 L. 2009The corroboration requirement "reflects a long-standing mistrust of extrajudicial confessions" ( Furby, 138 Ill.2d at 447 , 150 Ill.Dec. 534 , 563 N.E.2d 421 ), and it "stems from an attempt to assure the truthfulness of the confession and recognizes that the reliability of a confession `may be suspect if it is extracted from one who is under the pressure of a police investigation whose words may reflect the strain and confusion attending his predicament rather than a clear reflection of his past.'" Willingham, 89 Ill.2d at 359 , 59 Ill.Dec. 917 , 432 N.E.2d 861 , quoting Smith v. United Sta | 21 | 1983–2009 |
Wistrand v. People
green
2 sentences2013The defendant argued that the courts in Wistrand v. People, 213 Ill. 72 (1904), and People v. Rogers, 415 Ill. 343 (1953), reversed convictions that included age as an element because the only proof of age was the defendants’ out-of-court statements, violating the corpus delicti rule. ¶ 28 Modifying the holdings in Wistrand and Rogers, the court in Dalton changed the rule “as it holds that age is subject to the corroboration requirement” to allow the jury’s observation of the defendant to provide sufficient independent corroboration of his age. 2011In Wistrand v. People, 213 Ill. 72, 79 , 72 N.E. 748 (1904), our supreme court held that the prosecution must present some evidence corroborating every element of the crime charged to establish the corpus delicti. | 3 | 2011–2013 |
The People v. O'Neil
green
2 sentences1987It has been held that corroborating facts need not prove the corpus delicti independent of confession. ( People v. Lueder (1954), 3 Ill.2d 487, 488 , 121 N.E.2d 743, 744 .) Thus, in determining whether intercourse was established by evidence apart from the confession, the court could consider such evidence in light of the confession. 2 It is well established that the corroboration requirement is to assure the truthfulness of the confession and recognizes that the reliability of a confession "`may be suspect if it is extracted from one who is under the pressure of a police investigation who 1987It has been held that corroborating facts need not prove the corpus delicti independent of confession. ( People v. Lueder (1954), 3 Ill.2d 487, 488 , 121 N.E.2d 743, 744 .) Thus, in determining whether intercourse was established by evidence apart from the confession, the court could consider such evidence in light of the confession. 2 It is well established that the corroboration requirement is to assure the truthfulness of the confession and recognizes that the reliability of a confession "`may be suspect if it is extracted from one who is under the pressure of a police investigation who | 3 | 1983–1989 |
The PEOPLE v. Perfecto
green
2 sentences1984In Willingham, the Illinois Supreme Court, after stating: “The corroboration requirement stems from an attempt to assure the truthfulness of the confession and recognizes that the reliability of a confession ‘may be suspect if it is extracted from one who is under the pressure of a police investigation ***.’ ” 89 Ill. 2d 352, 359 , 432 N.E.2d 861 , cited to People v. Perfecto (1962), 26 Ill. 2d 228 , 186 N.E.2d 258 , and stated: “ ‘ “The true rule is that if there is evidence of corroborating circumstances which tend to prove the corpus delicti and correspond with the circumstances related in 1984In Willingham, the Illinois Supreme Court, after stating: “The corroboration requirement stems from an attempt to assure the truthfulness of the confession and recognizes that the reliability of a confession ‘may be suspect if it is extracted from one who is under the pressure of a police investigation ***.’ ” 89 Ill. 2d 352, 359 , 432 N.E.2d 861 , cited to People v. Perfecto (1962), 26 Ill. 2d 228 , 186 N.E.2d 258 , and stated: “ ‘ “The true rule is that if there is evidence of corroborating circumstances which tend to prove the corpus delicti and correspond with the circumstances related in | 2 | 1984–1991 |
The PEOPLE v. Norcutt
green
2 sentences1988(See People v. Taylor (1974), 58 Ill. 2d 69 ; People v. Norcutt (1970), 44 Ill. 2d 256 .) Proof of the corpus delicti committed consistently with the defendant’s admissions of guilt is all that the corroboration rule demands. 1982(E.g., People v. Holmes (1977), 67 Ill. 2d 236, 240 , citing People v. Norcutt (1970), 44 Ill. 2d 256, 263 ; People v. Melquist (1962), 26 Ill. 2d 22, 28 .) The corroboration requirement stems from an attempt to assure the truthfulness of the confession and recognizes that the reliability of a confession “may be suspect if it is extracted from one who is under the pressure of a police investigation — whose words may reflect the strain and confusion attending his predicament rather than a clear reflection of his past.” Smith v. United States (1954), 348 U.S. 147, 153 , 99 L. | 2 | 1982–1988 |
People v. Lueder
green
2 sentences1987It has been held that corroborating facts need not prove the corpus delicti independent of confession. ( People v. Lueder (1954), 3 Ill.2d 487, 488 , 121 N.E.2d 743, 744 .) Thus, in determining whether intercourse was established by evidence apart from the confession, the court could consider such evidence in light of the confession. 2 It is well established that the corroboration requirement is to assure the truthfulness of the confession and recognizes that the reliability of a confession "`may be suspect if it is extracted from one who is under the pressure of a police investigation who 1987It has been held that corroborating facts need not prove the corpus delicti independent of confession. ( People v. Lueder (1954), 3 Ill.2d 487, 488 , 121 N.E.2d 743, 744 .) Thus, in determining whether intercourse was established by evidence apart from the confession, the court could consider such evidence in light of the confession. 2 It is well established that the corroboration requirement is to assure the truthfulness of the confession and recognizes that the reliability of a confession "`may be suspect if it is extracted from one who is under the pressure of a police investigation who | 2 | 1983–1987 |
People v. Holmes
green
1 sentence2024Additionally, the State argues that the circuit court properly dismissed Feliciano’s ineffective assistance claim for failure to investigate and call alibi witnesses because Feliciano did not satisfy the corroboration requirement in section 122-2 of the Act. ¶ 15 At the outset, we note that “forfeiture is a limitation on the parties and not the reviewing court, and we may overlook forfeiture where necessary to obtain a just result or maintain a sound body of precedent.” People v. Holmes, 2016 IL App (1st) 132357, ¶ 65 . | 1 | 2024–2024 |
People v. Bowel
green
1 sentence2024The circuit court noted that, here, where the State failed to provide any meaningful evidence of the alleged confession’s voluntariness or reliability, it was unable to ascertain as much from the silent video feed alone. - 22 - 2024 IL App (2d) 240042-U found, pursuant to People v. Bowel, 111 Ill. 2d 58 (1986) and Chambers v. Mississippi, 410 U.S. 284 (1973), that “the most significant confessions should be corroborated, if possible.” The State argues that the court therefore erroneously required any evidence of reliability and voluntariness to be corroborated, because the recording statute do | 1 | 2024–2024 |
Chambers v. Mississippi
green
1 sentence2024The circuit court noted that, here, where the State failed to provide any meaningful evidence of the alleged confession’s voluntariness or reliability, it was unable to ascertain as much from the silent video feed alone. - 22 - 2024 IL App (2d) 240042-U found, pursuant to People v. Bowel, 111 Ill. 2d 58 (1986) and Chambers v. Mississippi, 410 U.S. 284 (1973), that “the most significant confessions should be corroborated, if possible.” The State argues that the court therefore erroneously required any evidence of reliability and voluntariness to be corroborated, because the recording statute do | 1 | 2024–2024 |
People v. McKown
green
1 sentence2023Correspondingly, where a defendant confesses to multiple offenses, the corroboration rule requires that there be independent evidence tending to show that defendant committed each of the offenses for which he was convicted.” People v. Sargent, 239 Ill. 2d 166, 185 (2010). ¶ 16 We find the decision in People v. McKown, 2021 IL App (4th) 190660 , instructive. | 1 | 2023–2023 |
People v. Hodges
green
1 sentence2017Id. at 18 . | 1 | 2017–2017 |
People v. Rogers
green
1 sentence2013The defendant argued that the courts in Wistrand v. People, 213 Ill. 72 (1904), and People v. Rogers, 415 Ill. 343 (1953), reversed convictions that included age as an element because the only proof of age was the defendants’ out-of-court statements, violating the corpus delicti rule. ¶ 28 Modifying the holdings in Wistrand and Rogers, the court in Dalton changed the rule “as it holds that age is subject to the corroboration requirement” to allow the jury’s observation of the defendant to provide sufficient independent corroboration of his age. | 1 | 2013–2013 |
People v. Collins
green
2 sentences2002Inapposite Authority The majority states that defendant's failure to attach a second affidavit or explain its absence is "fatal" to his petition. 202 Ill.2d at 66, 270 Ill.Dec. at 5 , 782 N.E.2d at 198 . 2002Inapposite Authority The majority states that defendant's failure to attach a second affidavit or explain its absence is "fatal" to his petition. 202 Ill.2d at 66, 270 Ill.Dec. at 5 , 782 N.E.2d at 198 . | 1 | 2002–2002 |
People v. Boclair
green
1 sentence2002Inapposite Authority The majority states that defendant’s failure to attach a second affidavit or explain its absence is “fatal” to his petition. 202 Ill. 2d at 66 . | 1 | 2002–2002 |
| People v. Schott green | 1 | 1993–1993 |
| People v. Collins green | 1 | 1993–1993 |
| In Re Custody of Brunken green | 1 | 1993–1993 |
| People v. Montes green | 1 | 1991–1991 |
| People v. Rocha green | 1 | 1991–1991 |
| People v. White green | 1 | 1991–1991 |
| People v. Webb green | 1 | 1989–1989 |
| People v. Calhoun green | 1 | 1988–1988 |
| People v. Taylor green | 1 | 1988–1988 |
| People v. Hamilton green | 1 | 1987–1987 |
| United States v. Robert E. Jones green | 1 | 1987–1987 |
| People v. Raseaitis green | 1 | 1986–1986 |
| People v. Avery green | 1 | 1986–1986 |
| People v. Aponte green | 1 | 1983–1983 |
| The PEOPLE v. Melquist neutral | 1 | 1982–1982 |
| People v. Holmes green | 1 | 1982–1982 |
| People v. Osborn green | 1 | 1981–1981 |
| People v. Secret green | 1 | 1981–1981 |
| Avant, Inc. v. Polaroid Corp. green | 1 | 1981–1981 |
| People v. Yarbrough green | 1 | 1981–1981 |
| People v. Brown green | 1 | 1977–1977 |
| People v. Williams neutral | 1 | 1977–1977 |
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.