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6 Illinois opinions name it 1 courts 1998–2026 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.
| Case | Followed | Cited |
|---|---|---|
People v. Jeffriesgreen2 sentences2026Thus, the exception under which an initial aggressor may still claim self-defense does not apply and defendant’s self-defense claim fails. - 13 - ¶ 44 In the alternative, defendant argues that his first degree murder conviction should be reduced to second degree murder based on his subjective but unreasonable belief in the need for self-defense. ¶ 45 To reduce a charge from first to second degree murder, the defendant bears the burden of proving by a preponderance of the evidence that one of the following mitigating factors was present at the time of killing: he either (1) acted under a sudden 2023Jeffries, 164 Ill. 2d at 121 .” (Emphasis added.) Id. ¶ 41. ¶ 71 The Guyton court agreed with the defendant’s premise that, in committing the acts that formed the basis of each offense, defendant had the same unreasonable belief in the need for self- defense. | 1 | 2 |
People v. Savickasgreen2 sentences1998See People v. Savickas , 230 Ill. 1998See People v. Savickas, 230 Ill. | 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. Jones
green
1 sentence2026“The determination of whether a defendant is guilty of first-degree murder or guilty of second-degree murder or was justified because acting in self-defense is a question for the finder of fact.” People v. Simon, 2011 IL App (1st) 091197, ¶ 52 . ¶ 50 Defendant acknowledges shooting Strenger but claims his belief in the need for self- defense was reasonable. “[T]he use of deadly force is only justified if the defendant reasonably believes that such force is necessary to prevent imminent death or great bodily harm.” (Internal quotation marks omitted.) People v. Jones, 2024 IL App (1st) 221555, ¶ | 1 | 2026–2026 |
People v. Simon
green
1 sentence2026“The determination of whether a defendant is guilty of first-degree murder or guilty of second-degree murder or was justified because acting in self-defense is a question for the finder of fact.” People v. Simon, 2011 IL App (1st) 091197, ¶ 52 . ¶ 50 Defendant acknowledges shooting Strenger but claims his belief in the need for self- defense was reasonable. “[T]he use of deadly force is only justified if the defendant reasonably believes that such force is necessary to prevent imminent death or great bodily harm.” (Internal quotation marks omitted.) People v. Jones, 2024 IL App (1st) 221555, ¶ | 1 | 2026–2026 |
People v. Guy
green
1 sentence2025And as recently explained by our supreme court, a defendant “who subjectively believes in the need for self- defense cannot be convicted of attempted first degree murder because the defendant would not have the specific intent to commit first degree murder.” People v. Guy, 2025 IL 129967, ¶ 47 . - 14 - ¶ 54 During the jury instruction conference, the trial court provided a detailed analysis of the six elements of self-defense as applied to defendant. | 1 | 2025–2025 |
People v. Jones
green
1 sentence2023App. 3d 943, 947 (1998). ¶ 44 “For completed murders (non-attempts), an unreasonable belief in the need for self- defense mitigates first degree murder to second degree murder but does not result in an outright acquittal.” People v. Jones, 2021 IL App (1st) 181266, ¶ 66 . | 1 | 2023–2023 |
People v. Hoffer
green
1 sentence2023Hoffer, 106 Ill. 2d at 194-95 . | 1 | 2023–2023 |
West American Insurance Co. v. Vago
green
2 sentences1998In West American Insurance Co. v. Vago , 197 Ill. 1998In West American Insurance Co. v. Vago, 197 Ill. | 1 | 1998–1998 |
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.