collective knowledge doctrine (Illinois) · Go Syfert
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collective knowledge doctrine in Illinois

8 Illinois opinions name it 1 courts 2007–2026 5 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 (11)

CaseFollowedCited
United States v. Roberto Rodriguezgreen
ca7 · 1987 · cited in 2 Illinois opinions naming this issue, 2020–2021
2 sentences

2021See, e.g., United States v. Rodriguez, 831 F.2d 162, 166 (7th Cir. 1987) (applying doctrine where local officer conducting - 11 - No. 1-19-0459 traffic stop at DEA’s request knew nothing about factual basis for agency’s suspicion); United States v. Celio, 945 F.2d 180, 183 (7th Cir. 1991) (applying doctrine where local officers who stopped and searched vehicle at DEA’s request knew only “bald assertion *** that [its agents] suspected drug trafficking.”). ¶ 38 Because we have found probable cause to arrest, we assume (because Spencer does not dispute) that police properly impounded the Mazda an

2020See, e.g., United States v. Rodriguez, 831 F.2d 162, 166 (7th Cir. 1987) (applying doctrine where local officer conducting traffic stop at DEA’s request knew nothing about factual basis for DEA’s suspicion); United States v. Celio, 945 F.2d 180, 183 (7th Cir. 1991) (applying doctrine where local officers who stopped and searched vehicle at DEA’s request knew only “bald assertion *** that [its agents] suspected drug trafficking.”).

22
United States v. Lino A. Celiogreen
ca7 · 1991 · cited in 2 Illinois opinions naming this issue, 2020–2021
2 sentences

2021See, e.g., United States v. Rodriguez, 831 F.2d 162, 166 (7th Cir. 1987) (applying doctrine where local officer conducting - 11 - No. 1-19-0459 traffic stop at DEA’s request knew nothing about factual basis for agency’s suspicion); United States v. Celio, 945 F.2d 180, 183 (7th Cir. 1991) (applying doctrine where local officers who stopped and searched vehicle at DEA’s request knew only “bald assertion *** that [its agents] suspected drug trafficking.”). ¶ 38 Because we have found probable cause to arrest, we assume (because Spencer does not dispute) that police properly impounded the Mazda an

2020See, e.g., United States v. Rodriguez, 831 F.2d 162, 166 (7th Cir. 1987) (applying doctrine where local officer conducting traffic stop at DEA’s request knew nothing about factual basis for DEA’s suspicion); United States v. Celio, 945 F.2d 180, 183 (7th Cir. 1991) (applying doctrine where local officers who stopped and searched vehicle at DEA’s request knew only “bald assertion *** that [its agents] suspected drug trafficking.”).

22
United States v. Roy W. Nafzgergreen
ca7 · 1992 · cited in 2 Illinois opinions naming this issue, 2020–2021
2 sentences

2021Id. at 252-253 . (citing United States v. Nafzger, 974 F.2d 906, 911 (7th Cir. 1992)).

2020Id. at 252-253 . (citing United States v. Nafzger, 974 F.2d 906, 911 (7th Cir. 1992)).

22
United States v. Robert Paul Kaplanskygreen
ca6 · 1994 · cited in 2 Illinois opinions naming this issue, 2007–2007
2 sentences

2007See United States v. Fernandez-Castillo, 324 F.3d 1114, 1118 (9th Cir. 2003); United States v. Kaplansky, 42 F.3d 320, 327 (6th Cir. 1994); United States v. Cutchin, 956 F.2d 1216, 1217-18 (D.C.

2007See United States v. Fernandez-Castillo, 324 F.3d 1114, 1118 (9th Cir. 2003); United States v. Kaplansky, 42 F.3d 320, 327 (6th Cir. 1994); United States v. Cutchin, 956 F.2d 1216, 1217-18 (D.C.

22
United States v. Anthony Cutchingreen
cadc · 1992 · cited in 2 Illinois opinions naming this issue, 2007–2007
2 sentences

2007See United States v. Fernandez-Castillo, 324 F.3d 1114, 1118 (9th Cir. 2003); United States v. Kaplansky, 42 F.3d 320, 327 (6th Cir. 1994); United States v. Cutchin, 956 F.2d 1216, 1217-18 (D.C.

2007See United States v. Fernandez-Castillo, 324 F.3d 1114, 1118 (9th Cir. 2003); United States v. Kaplansky, 42 F.3d 320, 327 (6th Cir. 1994); United States v. Cutchin, 956 F.2d 1216, 1217-18 (D.C.

22
United States v. Rigoberto Fernandez-Castillogreen
ca9 · 2003 · cited in 2 Illinois opinions naming this issue, 2007–2007
2 sentences

2007See United States v. Fernandez-Castillo, 324 F.3d 1114, 1118 (9th Cir. 2003); United States v. Kaplansky, 42 F.3d 320, 327 (6th Cir. 1994); United States v. Cutchin, 956 F.2d 1216, 1217-18 (D.C.

2007See United States v. Fernandez-Castillo, 324 F.3d 1114, 1118 (9th Cir. 2003); United States v. Kaplansky, 42 F.3d 320, 327 (6th Cir. 1994); United States v. Cutchin, 956 F.2d 1216, 1217-18 (D.C.

22
cluster 431092green
ca9 · 1984 · cited in 1 Illinois opinions naming this issue, 2026–2026
1 sentence

2026See United States v. Rubio, 727 F.2d 786, 797 (9th Cir. 1983) (“We are unpersuaded that a consent search may be validly qualified by the number of officers allowed to search, and we so hold.”); cf. People v. Whiles, 2024 IL App (4th) 231086, ¶¶ 29-37 (discussing United States v. Hensley, 469 U.S. 221 (1985) and applying the collective knowledge doctrine to hold that one officer’s knowledge was collectively imputed to another officer to support probable cause). ¶ 41 Finally, the record does not support a subsequent revocation of the consent given.

11
People v. Whilesgreen
illappct · 2024 · cited in 1 Illinois opinions naming this issue, 2026–2026
1 sentence

2026See United States v. Rubio, 727 F.2d 786, 797 (9th Cir. 1983) (“We are unpersuaded that a consent search may be validly qualified by the number of officers allowed to search, and we so hold.”); cf. People v. Whiles, 2024 IL App (4th) 231086, ¶¶ 29-37 (discussing United States v. Hensley, 469 U.S. 221 (1985) and applying the collective knowledge doctrine to hold that one officer’s knowledge was collectively imputed to another officer to support probable cause). ¶ 41 Finally, the record does not support a subsequent revocation of the consent given.

11
People v. Fonnergreen
illappct · 2008 · cited in 1 Illinois opinions naming this issue, 2023–2023
1 sentence

2023App. 3d 585, 593 (2007); see also People v. Fonner, 385 Ill.

11
People v. Ewinggreen
illappct · 2007 · cited in 1 Illinois opinions naming this issue, 2023–2023
2 sentences

2023Further, pursuant to the collective knowledge doctrine, “information known to all of the police officers acting in concert can be examined when determining whether the officer initiating the stop had reasonable suspicion to justify a Terry stop.” People v. Ewing, 377 Ill.

2023See Ewing, 377 Ill.

11
People v. Bussgreen
ill · 1999 · cited in 1 Illinois opinions naming this issue, 2023–2023
1 sentence

2023See, e.g., People v. Buss, 187 Ill. 2d 144, 204 (1999) (officers may rely - 11 - No. 1-20-0936 on each other’s collective knowledge to establish probable cause); Hensley, 469 U.S. at 230-32 . ¶ 41 Neither petitioner nor the Bass majority (nor Smith following it) claims that the alleged constitutional problem with arrests based on investigative alerts results from the application of the collective-knowledge doctrine in this context.

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 (1)

CaseCitedYears
United States v. Hensley green
scotus · 1985
2 sentences

2026See United States v. Rubio, 727 F.2d 786, 797 (9th Cir. 1983) (“We are unpersuaded that a consent search may be validly qualified by the number of officers allowed to search, and we so hold.”); cf. People v. Whiles, 2024 IL App (4th) 231086, ¶¶ 29-37 (discussing United States v. Hensley, 469 U.S. 221 (1985) and applying the collective knowledge doctrine to hold that one officer’s knowledge was collectively imputed to another officer to support probable cause). ¶ 41 Finally, the record does not support a subsequent revocation of the consent given.

2024In an era when criminal suspects are increasingly mobile and increasingly likely to flee across jurisdictional boundaries, this rule is a matter of common sense: it minimizes the volume of information concerning suspects that must be transmitted to other - 13 - jurisdictions and enables police in one jurisdiction to act promptly in reliance on information from another jurisdiction.” Id. at 231 . ¶ 35 The Supreme Court in Hensley anticipated an objection to using this collective- knowledge principle from Whiteley: in Whiteley, there was a warrant, whereas in Hensley, there was no warrant.

52020–2026

Statutes the citing opinions construe

IL § 725 ILCS 5/122-1 (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

TX 22 (2015–2025) OH 16 (2011–2026) PA 15 (2015–2025) WI 15 (2000–2025) MA 10 (1994–2024) OR 9 (2000–2025) DC 9 (1993–2025) IL 8 (2007–2026) IN 7 (2012–2025) CA 7 (2002–2021) CT 6 (2007–2019) ID 6 (2018–2026) NV 5 (2018–2018) DE 5 (2015–2025) VA 4 (2016–2021) MN 4 (2010–2014) KY 4 (2017–2023) KS 4 (2013–2024) MD 3 (1992–2025) OK 3 (2014–2021) NE 3 (2021–2023) WY 3 (2019–2022) UT 3 (2007–2011) IA 2 (1981–2016) SD 2 (1998–2013) AK 2 (2018–2018) GA 2 (2007–2015) ND 2 (1989–2008) MI 2 (1993–2003) TN 2 (2019–2019)

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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