modified instruction (Illinois) · Go Syfert
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modified instruction in Illinois

59 Illinois opinions name it 2 courts 1879–2026 12 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 (15)

CaseFollowedCited
Thompson v. MCA Distributing, Music Corp. of Americagreen
illappct · 1994 · cited in 2 Illinois opinions naming this issue, 2003–2003
2 sentences

2003See Thompson v. MCA Distributing, Music Corp. of America, 257 Ill.

2003See Thompson v. MCA Distributing, Music Corp. of America , 257 Ill.

22
Turner v. Williamsgreen
illappct · 2001 · cited in 2 Illinois opinions naming this issue, 2003–2003
2 sentences

2003See Turner v. Williams, 326 Ill.

2003See Turner v. Williams , 326 Ill.

22
Harris v. Cropmate Companygreen
illappct · 1999 · cited in 2 Illinois opinions naming this issue, 2002–2002
2 sentences

2002See Harris v. Cropmate Co., 302 Ill.App.3d 364, 365 , 235 Ill.Dec. 795 , 706 N.E.2d 55 (1999); First Midwest Trust Co. v. Rogers, 296 Ill.App.3d 416, 427 , 233 Ill.Dec. 833 , 701 N.E.2d 1107 (1998); see also Handbook of Illinois Evidence § 702.4, at 626 ("Application of the Frye standard calls for a judicial determination * * * that the test's reliability is generally accepted in the particular scientific field in which the test belongs").

2002See Harris v. Cropmate Co., 302 Ill.

22
Chapski v. Copley Pressgreen
ill · 1982 · cited in 5 Illinois opinions naming this issue, 1983–2003
2 sentences

1990We reiterate the modified rule this court announced in Chapski: “[A] written or oral statement is to be considered in context, with the words and the implications therefrom given their natural and obvious meaning; if, as so construed, the statement may reasonably be innocently interpreted or reasonably be interpreted as referring to someone other than the plaintiff it cannot be actionable per se.” (Chapski, 92 Ill. 2d at 352 .) It is self-evident that a statement “reasonably” capable of a nondefamatory interpretation, given its verbal or literary context, should be so interpreted.

1984Further, the modified rule of Chapski v. Copley Press (1982), 92 Ill. 2d 344 , 442 N.E.2d 195 , has been applied with an emphasis on protecting an individual’s interest in vindicating his good name and reputation as well as first amendment interests.

15
People v. Bannistergreen
ill · 2008 · cited in 1 Illinois opinions naming this issue, 2026–2026
1 sentence

2026Likewise, there was no error in allowing the recording into evidence at trial over defense counsel’s identical objection. ¶ 33 Gabrys’s third argument on appeal is that the circuit court erred when it refused to issue a modified instruction on the elements of harassment by telephone based on the United States Supreme Court’s decision in Counterman. ¶ 34 “If IPI instructions contain an applicable instruction on a subject about which the trial court determines the jury should be instructed, the trial court must use that instruction, unless the court determines that the instruction does not accur

11
People v. Hillgreen
illappct · 1995 · cited in 1 Illinois opinions naming this issue, 2025–2025
1 sentence

2025Thus, the defendant argues, that the State was precluded from arguing, as it did in closing, that the intent to kill Chairs or Holman transferred to the unintended victims on the lot, and the trial court erred when it provided instruction on the same. ¶ 80 Here, the law is clear: “a person may be properly convicted under the theory of transferred intent even if the State does not specifically allege that theory in the charging instrument.” People v. Hill, 276 Ill.

11
People v. Lawtongreen
ill · 2004 · cited in 1 Illinois opinions naming this issue, 2025–2025
1 sentence

2025The factual predicate for defendant’s claim of conflict and ineffectiveness simply does not exist. ¶ 59 While an attorney cannot be expected to argue his own ineffectiveness when it would create a conflict, People v. Lawton, 212 Ill. 2d 285, 296 (2004), trial counsel never claimed to be ineffective.

11
People v. Enochgreen
ill · 1988 · cited in 1 Illinois opinions naming this issue, 2025–2025
1 sentence

2025People v. Enoch, 122 Ill. 2d 176, 186 (1988) (to preserve a claim for review, a defendant must both object at trial and include the alleged error in a written posttrial motion).

11
People v. Williamsgreen
ill · 1991 · cited in 1 Illinois opinions naming this issue, 2021–2021
1 sentence

2021See, e.g., People v. Williams, 147 Ill. 2d 173, 232 (1991) (“The testimony of an accomplice witness ‘ “has inherent weaknesses, being testimony of a confessed criminal and fraught with dangers of motives such as malice towards the accused, fear, threats, promises or hopes of leniency, or benefits from the prosecution.” ’ ” (quoting People v. Young, 128 Ill. 2d 1, 47-48 (1989), quoting People v. Hermens, 5 Ill. 2d 277, 285 (1955))).

11
Rice v. Ford Motor Co.green
illappct · 2000 · cited in 1 Illinois opinions naming this issue, 2021–2021
1 sentence

2021Under the modified rule, there was “no restriction on the court’s analysis based on when the plaintiff’s ‘reasonable diligence,’ or lack thereof, occurred, i.e., before or after the expiration of the statute of limitations.” Rice v. Ford Motor Co., 316 Ill.

11
Foutch v. O'BRYANTgreen
ill · 1984 · cited in 1 Illinois opinions naming this issue, 2021–2021
1 sentence

2021“Any doubts which may arise from the incompleteness of the record will be resolved against the appellant.” Foutch v. O’Bryant, 99 Ill. 2d 389, 392 (1984). ¶ 89 Moreover, a comparison of People’s Instruction 11 and IPI Criminal 3.14 demonstrates that People’s Instruction 11 was not a modified instruction such that defendant’s forfeiture should be excused.

11
People v. Hermensgreen
ill · 1955 · cited in 1 Illinois opinions naming this issue, 2021–2021
1 sentence

2021See, e.g., People v. Williams, 147 Ill. 2d 173, 232 (1991) (“The testimony of an accomplice witness ‘ “has inherent weaknesses, being testimony of a confessed criminal and fraught with dangers of motives such as malice towards the accused, fear, threats, promises or hopes of leniency, or benefits from the prosecution.” ’ ” (quoting People v. Young, 128 Ill. 2d 1, 47-48 (1989), quoting People v. Hermens, 5 Ill. 2d 277, 285 (1955))).

11
People v. Younggreen
ill · 1989 · cited in 1 Illinois opinions naming this issue, 2021–2021
1 sentence

2021See, e.g., People v. Williams, 147 Ill. 2d 173, 232 (1991) (“The testimony of an accomplice witness ‘ “has inherent weaknesses, being testimony of a confessed criminal and fraught with dangers of motives such as malice towards the accused, fear, threats, promises or hopes of leniency, or benefits from the prosecution.” ’ ” (quoting People v. Young, 128 Ill. 2d 1, 47-48 (1989), quoting People v. Hermens, 5 Ill. 2d 277, 285 (1955))).

11
People v. Ramseygreen
ill · 2010 · cited in 1 Illinois opinions naming this issue, 2013–2013
11
Holland v. Quinngreen
illappct · 1978 · cited in 1 Illinois opinions naming this issue, 1990–1990
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 (45)

CaseCitedYears
People v. Gutierrez green
colo · 1981
2 sentences

2019Defendants should be allowed to withdraw properly entered guilty pleas only in order to avoid manifest injustice. [Citation.].” Id. ¶ 60 The Colorado court then adopted “a modified standard” for actual innocence claims after guilty pleas, in which the “defendant must present evidence from which the trial court may reasonably conclude that: (1) the newly discovered evidence was discovered after the entry of the plea, and, in the exercise of reasonable diligence by the defendant and his or her counsel, could not have been earlier discovered; (2) the charges that the People filed against the defe

2019Defendants should be allowed to withdraw properly entered guilty pleas only in order to avoid manifest injustice. [Citation.].” Id. ¶ 60 The Colorado court then adopted “a modified standard” for actual innocence claims after guilty pleas, in which the “defendant must present evidence from which the trial court may reasonably conclude that: (1) the newly discovered evidence was discovered after the entry of the plea, and, in the exercise of reasonable diligence by the defendant and his or her counsel, could not have been earlier discovered; (2) the charges that the People filed against the defe

32018–2019
Morus v. Kapusta green
illappct · 2003
2 sentences

2021App. 3d at 489 . ¶ 53 On appeal, the appellate court found the modified instruction on life expectancy “was warranted and not in error.” Id. at 493 .

2021App. 3d at 489 . ¶ 53 On appeal, the appellate court found the modified instruction on life expectancy “was warranted and not in error.” Id. at 493 .

22021–2021
Babikian v. Mruz green
illappct · 2011
2 sentences

2018Despite Our Disagreement With Babikian, We Find No Evidence, in the Present Case, of Duplicative Damages ¶ 55 In Babikian, the First District concluded: “In the absence of some supporting evidence in the record, the defendant’s claim that the modified instruction and the verdict form induced the jury to award the plaintiff a double recovery for her mental distress is mere conjecture.” Babikian, 2011 IL App (1st) 102579, ¶ 20 .

2017Despite Our Disagreement With Babikian , We Find No Evidence, in the Present Case, of Duplicative Damages ¶ 55 In Babikian , the First District concluded: "In the absence of some supporting evidence in the record, the defendant's claim that the modified instruction and the verdict form induced the jury to award the plaintiff a double recovery for her mental distress is mere conjecture." Babikian , 2011 IL App (1st) 102579 , ¶ 20, 353 Ill.Dec. 831 , 956 N.E.2d 959 .

22017–2018
People v. Sharp green
illappct · 2015
2 sentences

2015People v. Sharp, 2015 IL App (1st) 130438, ¶¶ 79-80 . ¶5 For the following reasons, we do not find defendant's arguments persuasive. ¶6 BACKGROUND ¶7 I.

2015People v. Sharp, 2015 IL App (1st) 130438, ¶¶ 79-80 . ¶5 For the following reasons, we do not find defendant’s arguments persuasive. ¶6 BACKGROUND ¶7 I.

22015–2015
People v. Minniefield green
illappct · 2015
2 sentences

2015People v. Minniefield, 2014 IL App (1st) 130535 . ¶3 While defendant's appeal of the second-stage dismissal of his postconviction petition was pending, defendant filed on November 27, 2013, a document entitled a "Motion to Vacate Conviction/Sentence as Void." The 2 No. 1-14-1094 document claimed that he was wrongly sentenced under a firearm enhancement provision because the jury was incorrectly instructed under a modified instruction. ¶4 On this appeal, defendant characterizes this document as a section 2-1401 petition (735 ILCS 5/2-1401(a) (West 2012)), but concedes that he "chose the incorre

2015People v. Minniefield, 2014 IL App (1st) 130535 . ¶3 While defendant’s appeal of the second-stage dismissal of his postconviction petition was pending, defendant filed on November 27, 2013, a document entitled a “Motion to Vacate Conviction/Sentence as Void.” The document claimed that he was wrongly sentenced under a firearm enhancement provision because the jury was incorrectly instructed under a modified instruction. ¶4 On this appeal, defendant characterizes this document as a section 2-1401 petition (735 ILCS 5/2-1401(a) (West 2012)), but concedes that he “chose the incorrect vehicle to pr

22015–2015
People v. Jenkins green
ill · 1977
2 sentences

2014Jenkins, 69 Ill. 2d at 66 . ¶ 85 The plaintiff argues that the modified instruction did not allow the jury to hold the UCMC responsible for the conduct of nurse Harmon.

2014Jenkins, 69 Ill. 2d at 66 . - 13 - ¶ 85 The plaintiff argues that the modified instruction did not allow the jury to hold the UCMC responsible for the conduct of nurse Harmon.

22014–2014
Dillon v. Evanston Hospital green
ill · 2002
2 sentences

2014Dillon, 199 Ill. 2d at 505 . ¶ 78 The plaintiff maintains that it was error to give the UCMC's modified instruction.

2014Dillon, 199 Ill. 2d at 505 . ¶ 78 The plaintiff maintains that it was error to give the UCMC’s modified instruction.

22014–2014
People v. Carini green
illappct · 1986
2 sentences

2004The trial court ruled that the proposed modification was in accordance with a similar instruction approved in People v. Carini, 151 Ill.

2004In People v. Carini, 151 Ill.

22004–2004
Smith v. City of Evanston green
illappct · 1994
2 sentences

2003Kamm argues that it was error to use this modified instruction, first proposed in Smith v. City of Evanston, 260 Ill.

2003Kamm argues that it was error to use this modified instruction, first proposed in Smith v. City of Evanston , 260 Ill.

22003–2003
Wind v. Hy-Vee Food Stores, Inc. green
illappct · 1995
2 sentences

1999While we agree with Nilsson that it was error for the lower court to instruct the jury with defendants’ modified instruction since Nilsson’s instruction fairly and accurately stated the law (Wind, 272 Ill.

1999While we agree with Nilsson that it was error for the lower court to instruct the jury with defendants' modified instruction since Nilsson's instruction fairly and accurately stated the law ( Wind , 272 Ill.

21999–1999
NWI International, Inc. v. Edgewood Bank green
illappct · 1997
2 sentences

1999App. 3d at 154 , 650 N.E.2d at 261 ), we do not agree that Nilsson’s right to a fair trial has been seriously prejudiced as a result thereof (NWI, 291 Ill.

1999App. 3d at 154 , 650 N.E.2d at 261 ), we do not agree that Nilsson's right to a fair trial has been seriously prejudiced as a result thereof ( NWI , 291 Ill.

21999–1999
Lill v. Lill green
ill · 1960
2 sentences

1997In Lill, the court modified this rule: "[A] voluntary conveyance by either party to a marriage contract, of his or her real estate, made without the knowledge or consent of the other on the eve, or in contemplation, of marriage, is prima facie a fraud upon the other’s marital rights, and the burden is upon the grantee to establish its validity. *** Not every voluntary conveyance is in fraud of the rights of the intended spouse, and if it be the intent of the grantor to provide for his children, and not to defraud his wife, such conveyance will not be held to be fraudulent where the advancement

1997In Lill, the court modified this rule: "[A] voluntary conveyance by either party to a marriage contract, of his or her real estate, made without the knowledge or consent of the other on the eve, or in contemplation, of marriage, is prima facie a fraud upon the other’s marital rights, and the burden is upon the grantee to establish its validity. *** Not every voluntary conveyance is in fraud of the rights of the intended spouse, and if it be the intent of the grantor to provide for his children, and not to defraud his wife, such conveyance will not be held to be fraudulent where the advancement

21997–1997
People v. Scott green
illappct · 1993
1 sentence

2024But the trial court modified the instruction to require two verdict forms, “guilty” and “not guilty.” Id.

12024–2024
Fennell v. Illinois Central R.R. Co. green
ill · 2013
1 sentence

2023Co., 2012 IL 113812, ¶ 12 , 987 N.E.2d 355 .

12023–2023
People v. James green
illappct · 2002
1 sentence

2022After expressing bewilderment at why the State chose to proceed the way it did and offer a modified instruction, why the defense raised no objection, and why the trial court gave an erroneous objection, we held, “[t]he jury instruction as to sexual penetration was clearly erroneous.” James, 331 Ill.

12022–2022
Virginia v. Black green
scotus · 2003
2 sentences

2018The speaker need not actually intend to carry out the threat." See Black , 538 U.S. at 359 -60 , 123 S.Ct. 1536 ; Dye , 2015 IL App (4th) 130799 , ¶ 9, 394 Ill.Dec. 986 , 37 N.E.3d 465 .

2018The speaker need not actually intend to carry out the threat." See Black , 538 U.S. at 359 -60 , 123 S.Ct. 1536 ; Dye , 2015 IL App (4th) 130799 , ¶ 9, 394 Ill.Dec. 986 , 37 N.E.3d 465 .

12018–2018
People v. Dye green
illappct · 2015
2 sentences

2018The speaker need not actually intend to carry out the threat." See Black , 538 U.S. at 359 -60 , 123 S.Ct. 1536 ; Dye , 2015 IL App (4th) 130799 , ¶ 9, 394 Ill.Dec. 986 , 37 N.E.3d 465 .

2018The speaker need not actually intend to carry out the threat." See Black , 538 U.S. at 359 -60 , 123 S.Ct. 1536 ; Dye , 2015 IL App (4th) 130799 , ¶ 9, 394 Ill.Dec. 986 , 37 N.E.3d 465 .

12018–2018
Babikian v. Mruz green
illappct · 2011
12017–2017
People v. Burnom green
illappct · 2003
12004–2004
First Midwest Trust Co. v. Rogers green
illappct · 1998
12002–2002
Nunley v. Mares green
illappct · 1983
11993–1993
Berry v. American Commercial Barge Lines neutral
illappct · 1983
11992–1992
Law v. Central Illinois Public Service Co. green
illappct · 1980
11992–1992
People v. Fierer green
ill · 1988
11990–1990
Alvis v. Ribar green
ill · 1981
11989–1989
People v. Cloyd green
illappct · 1987
11989–1989
People v. Jones green
ill · 1979
11989–1989
People v. Elliott green
illappct · 1986
11989–1989
People v. Sweeney green
illappct · 1969
11986–1986
Costello v. Capital Cities Media, Inc. green
illappct · 1982
11984–1984
Ryan v. Fleischman green
illappct · 1978
11983–1983
People v. Bailey green
illappct · 1973
11982–1982
Avance v. Thompson green
ill · 1944
11963–1963
Funk v. Eggleston green
· 1879
11934–1934
Zimmer v. Sennott neutral
ill · 1890
11934–1934
Morrison v. Schorr green
· 1902
11934–1934
Hopps v. People green
ill · 1863
11920–1920
People v. Hoban neutral
ill · 1909
11916–1916
Chicago & Alton Railway Co. v. Averill green
ill · 1906
11908–1908
City of Chicago v. Bixby neutral
ill · 1876
11907–1907

Statutes the citing opinions construe

IL § 725 ILCS 5/122-1 (5) IL § 735 ILCS 5/2-1401 (5) IL § 720 ILCS 5/8-4 (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

CA 156 (1909–2026) IL 59 (1879–2026) TX 41 (1915–2025) FL 32 (1938–2025) NJ 32 (1978–2022) NM 24 (1974–2025) MO 21 (1889–2023) IN 20 (1911–2023) OH 20 (1936–2023) PA 20 (1940–2024) ID 15 (1990–2021) WA 15 (1927–2026) CO 14 (1877–2026) OR 13 (1879–2026) MD 13 (1925–2025) CT 13 (1959–2016) MI 12 (1978–2025) WV 11 (1912–2023) AL 10 (1911–2013) OK 10 (1935–2012) WI 8 (1970–2026) AZ 8 (1934–2007) MN 8 (1931–2024) MA 7 (1987–2019) AR 7 (1905–2002) KS 6 (1931–2017) IA 6 (1908–2020) NV 6 (2012–2018) NY 6 (1960–2026) KY 6 (1933–2019) DE 5 (1959–1988) MS 5 (1988–2014) UT 5 (1985–2024) SD 5 (1896–2024) ND 5 (1893–2023) GA 4 (1948–2025) VA 4 (1885–1990) NC 4 (1924–2026) MT 4 (1921–2012) HI 4 (2010–2016) AK 3 (1978–2022) LA 3 (1997–2013) NH 2 (2005–2011) WY 2 (1973–1973) VT 2 (2007–2009) TN 2 (2002–2015) RI 2 (1981–1987) DC 2 (1982–2001) SC 2 (2016–2020)

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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