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57 Illinois opinions name it 2 courts 1979–2026 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.
| Case | Followed | Cited |
|---|---|---|
Mathews v. Eldridgegreen2 sentences2025Williams, 139 Ill. 2d at 45 (quoting Boddie, 401 U.S. at 376 ). - 16 - ¶ 46 Following this court’s precedent in Williams, 139 Ill. 2d at 28, 63 , and the Mathews factors (Mathews v. Eldridge, 424 U.S. 319, 333 (1976)) applied there, I would conclude that the Cook/Sangamon County venue statute in this case is arbitrary and unreasonable, effectively deprives plaintiff of its right to meaningful access to the legal process, and violates due process. 2025Williams, 139 Ill. 2d at 45 (quoting Boddie, 401 U.S. at 376 ). - 16 - ¶ 46 Following this court’s precedent in Williams, 139 Ill. 2d at 28, 63 , and the Mathews factors (Mathews v. Eldridge, 424 U.S. 319, 333 (1976)) applied there, I would conclude that the Cook/Sangamon County venue statute in this case is arbitrary and unreasonable, effectively deprives plaintiff of its right to meaningful access to the legal process, and violates due process. | 7 | 27 |
In Re Andrea F.green2 sentences2020See M.H., 196 Ill. 2d at 363-64; see also Andrea F., 208 Ill. 2d at 165 . ¶ 48 Our application of the Mathews factors to the case at bar demonstrates that due process does not require this court to vacate the proceedings following the dispositional hearing. 2020See M.H., 196 Ill. 2d at 363-64; see also Andrea F., 208 Ill. 2d at 165 . ¶ 48 Our application of the Mathews factors to the case at bar demonstrates that due process does not require this court to vacate the proceedings following the dispositional hearing. | 5 | 5 |
In Re MRgreen2 sentences2015App. 3d 167, 176 (2004) (applying Mathews factors in the context of termination proceedings); In re M.R., 316 Ill. 2015App. 3d 167, 176 (2004) (applying Mathews factors in the context of termination proceedings); In re M.R., 316 Ill. | 3 | 3 |
Lassiter v. Department of Social Servs. of Durham Cty.green2 sentences1986Ed. 2d 640 , 101 S. Ct. 2153 .) Under the Mathews test, three distinct factors are to be balanced: (1) the private interests affected by the proceedings; (2) the risk of erroneous deprivation of private interests resulting from the State’s chosen procedure; and (3) the countervailing State interest supporting use of the challenged procedure. 1986Ed. 2d 640 , 101 S. Ct. 2153 .) Under the Mathews test, three distinct factors are to be balanced: (1) the private interests affected by the proceedings; (2) the risk of erroneous deprivation of private interests resulting from the State’s chosen procedure; and (3) the countervailing State interest supporting use of the challenged procedure. | 2 | 5 |
People v. Botruffgreen2 sentences2011In order to determine whether procedures are constitutionally sufficient, courts balance three factors: "First, the private interest that will be affected by the official action; second, the risk of an erroneous deprivation of such interest through the procedures used, and the probable value, if any, of additional or substitute procedural safeguards; and finally, the Government's interest, including the function involved and the fiscal and administrative burdens that the additional or substitute procedural requirement would entail." Mathews, 424 U.S. at 335 , 96 S.Ct. 893 ; see also People v. 2011In order to determine whether procedures are constitutionally sufficient, courts balance three factors: “First, the private interest that will be affected by the official action; second, the risk of an erroneous deprivation of such interest through the procedures used, and the probable value, if any, of additional or substitute procedural safeguards; and finally, the Government’s interest, including the function involved and the fiscal and administrative burdens that the additional or substitute procedural requirement would entail.” Mathews, 424 U.S. at 335 ; see also People v. Botruff, 212 Il | 2 | 2 |
In Re Vanessa C.green2 sentences2001See also Vanessa C., 316 Ill. 2001See also Vanessa C., 316 Ill. | 2 | 2 |
Luckett v. Jettgreen2 sentences1999With respect to the first and second prongs of the Mathews analysis, the court reasoned that, because many claimants appear pro se before the Department, “the [claimants’] interest would be better served by maintaining the informal nature of the present investigatory system, rather than injecting formalistic requirements with which only trained advocates could comply.” Luckett, 966 F.2d at 214-15. 1999With respect to the first and second prongs of the Mathews analysis, the court reasoned that, because many claimants appear pro se before the Department, “the [claimants’] interest would be better served by maintaining the informal nature of the present investigatory system, rather than injecting formalistic requirements with which only trained advocates could comply.” Luckett, 966 F.2d at 214-15. | 2 | 2 |
In Re AAgreen2 sentences2003In re A.A., 324 Ill. 2003In re A.A., 324 Ill. | 1 | 3 |
Santosky v. Kramergreen2 sentences2001Ed. 2d 599 , 102 S. Ct. 1388 (determining the standard of proof required in a parental rights termination case and applying the Mathews factors, the Court: (1) reiterated the parent’s fundamental liberty interest in raising a child; (2) noted an increased burden of proof could reduce the possibility of erroneous terminations; and (3) stated a higher standard would promote the welfare of the child through accurate decisions without any burdens for the State or the fact finder). 2001Ed. 2d 599 , 102 S. Ct. 1388 (determining the standard of proof required in a parental rights termination case and applying the Mathews factors, the Court: (1) reiterated the parent’s fundamental liberty interest in raising a child; (2) noted an increased burden of proof could reduce the possibility of erroneous terminations; and (3) stated a higher standard would promote the welfare of the child through accurate decisions without any burdens for the State or the fact finder). | 1 | 3 |
People v. Maurice B. (In Re M.B.)green2 sentences2022In re M.B., 2019 IL App (2d) 181008, ¶ 20 (citing Mathews v. Eldridge, 424 U.S. 319, 335 (1976)). 2022In re M.B., 2019 IL App (2d) 181008, ¶ 20 (citing Mathews v. Eldridge, 424 U.S. 319, 335 (1976)). | 1 | 2 |
In Re MHgreen2 sentences2019See M.H., 196 Ill. 2d at 362. 2019See M.H., 196 Ill. 2d at 362. | 1 | 2 |
In re the Detention of Morgangreen2 sentences2011Morgan, 253 P.3d at 403 . ¶ 70 Based on our analysis of the Mathews factors, which is supported by the Illinois case of Akers and case law from other jurisdictions considering analogous statutes, we find that there is no due process right to a fitness evaluation in the case of a proceeding under the Act. -21- ¶ 71 III. 2011Morgan, 253 P.3d at 403 . ¶ 70 Based on our analysis of the Mathews factors, which is supported by the Illinois case of Akers and case law from other jurisdictions considering analogous statutes, we find that there is no due process right to a fitness evaluation in the case of a proceeding under the Act. -21- ¶ 71 III. | 1 | 2 |
Krimstock v. Kellyred2 sentences2011Id. at 67. ¶ 78 Persuaded by the approach taken in Krimstock, the circuit court in this case reasoned that the vehicle-forfeiture provisions of Illinois' Criminal Code were facially invalid and unenforceable under the due process clauses of the Illinois Constitution and the fifth and fourteenth amendments of the United States Constitution because they did not provide any mechanism for a prompt, probable cause hearing after a vehicle was seized where claimants could test the State's right to retain their vehicles while they awaited trial on the merits of the forfeiture action and where the *109 2011Id. at 67 . ¶ 78 Persuaded by the approach taken in Krimstock, the circuit court in this case reasoned that the vehicle-forfeiture provisions of Illinois’ Criminal Code were facially invalid and unenforceable under the due process clauses of the Illinois Constitution and the fifth and fourteenth amendments of the United States Constitution because they did not provide any mechanism for a prompt, probable cause hearing after a vehicle was seized where claimants could test the State’s right to retain their vehicles while they awaited trial on the merits of the forfeiture action and where the Sta | 1 | 2 |
Federal Deposit Insurance v. Mallengreen2 sentences2004Mallen, 486 U.S. at 242 , 100 L. 2004Mallen, 486 U.S. at 242 , 100 L. | 1 | 2 |
In Re DRgreen2 sentences2001In D.R., 307 Ill. 2001In D.R., 307 Ill. | 1 | 2 |
People v. Cardonagreen1 sentence2026See id. (citing Mathews v. Eldridge, 424 U.S. 319, 335 (1976)). | 1 | 1 |
People Ex Rel. Williams v. Rhodesgreen2 sentences2026Williams v. Rhodes, 185 Ill. App. 3d 114, 116-18 (1989) (applying the Mathews factors to hold a stepfather did not have a due process right to counsel when opposing the issuance of an order of protection). 2026Williams v. Rhodes, 185 Ill. App. 3d 114, 116-18 (1989) (applying the Mathews factors to hold a stepfather did not have a due process right to counsel when opposing the issuance of an order of protection). | 1 | 1 |
People v. Grabowgreen2 sentences2025See People v. Jones, 2024 IL App (1st) 221555, ¶ 54 (“[A] defendant is entitled to an instruction as to any recognized defense for which there exists evidence sufficient for a reasonable jury to find in his favor.” (Internal quotation marks omitted.)); People v. Grabow, 2022 IL App (2d) 210151, ¶ 20 (same); People v. Kratovil, 351 Ill. 2025See People v. Jones, 2024 IL App (1st) 221555, ¶ 54 (“[A] defendant is entitled to an instruction as to any recognized defense for which there exists evidence sufficient for a reasonable jury to find in his favor.” (Internal quotation marks omitted.)); People v. Grabow, 2022 IL App (2d) 210151, ¶ 20 (same); People v. Kratovil, 351 Ill. | 1 | 1 |
People v. Jonesgreen2 sentences2025See People v. Jones, 2024 IL App (1st) 221555, ¶ 54 (“[A] defendant is entitled to an instruction as to any recognized defense for which there exists evidence sufficient for a reasonable jury to find in his favor.” (Internal quotation marks omitted.)); People v. Grabow, 2022 IL App (2d) 210151, ¶ 20 (same); People v. Kratovil, 351 Ill. 2025See People v. Jones, 2024 IL App (1st) 221555, ¶ 54 (“[A] defendant is entitled to an instruction as to any recognized defense for which there exists evidence sufficient for a reasonable jury to find in his favor.” (Internal quotation marks omitted.)); People v. Grabow, 2022 IL App (2d) 210151, ¶ 20 (same); People v. Kratovil, 351 Ill. | 1 | 1 |
Poeple v. Robert S.green2 sentences2025Balancing the Mathews Factors ¶ 43 After balancing the above Mathews factors, we conclude the City “ ‘met the fundamental requirements of due process—the opportunity to be heard at a meaningful time and - 18 - in a meaningful manner.’ ” Piasa Armory, LLC, 2025 IL 130539 , ¶ 15 (quoting In re Robert S., 213 Ill. 2d 30, 49 (2004)). 2025Balancing the Mathews Factors ¶ 43 After balancing the above Mathews factors, we conclude the City “ ‘met the fundamental requirements of due process—the opportunity to be heard at a meaningful time and - 18 - in a meaningful manner.’ ” Piasa Armory, LLC, 2025 IL 130539 , ¶ 15 (quoting In re Robert S., 213 Ill. 2d 30, 49 (2004)). | 1 | 1 |
People v. Kratovilgreen2 sentences2025See People v. Jones, 2024 IL App (1st) 221555, ¶ 54 (“[A] defendant is entitled to an instruction as to any recognized defense for which there exists evidence sufficient for a reasonable jury to find in his favor.” (Internal quotation marks omitted.)); People v. Grabow, 2022 IL App (2d) 210151, ¶ 20 (same); People v. Kratovil, 351 Ill. 2025See People v. Jones, 2024 IL App (1st) 221555, ¶ 54 (“[A] defendant is entitled to an instruction as to any recognized defense for which there exists evidence sufficient for a reasonable jury to find in his favor.” (Internal quotation marks omitted.)); People v. Grabow, 2022 IL App (2d) 210151, ¶ 20 (same); People v. Kratovil, 351 Ill. | 1 | 1 |
Williams v. Illinois State Scholarship Commissiongreen2 sentences2025Williams, 139 Ill. 2d at 62 . ¶ 26 Balancing all of the Mathews factors ultimately yields the conclusion that section 2-101.5 is not unconstitutional as applied specifically to plaintiff because requiring plaintiff to litigate in Sangamon County does not deprive it of the opportunity to be heard at a meaningful time and in a meaningful manner. 2025Id. at 67-73 . ¶ 20 In the instant case, the circuit court largely considered the “convenience” of Madison County and the “inconvenience” of Sangamon County as a forum for plaintiff in determining that the first two Mathews factors weighed heavily in -8- plaintiff’s favor. | 1 | 1 |
| People v. Deleongreen | 1 | 1 |
| Kaley v. United Statesgreen | 1 | 1 |
| Grimm v. Calicagreen | 1 | 1 |
| PASSALINO v. City of Ziongreen | 1 | 1 |
| In re Alexander V.green | 1 | 1 |
| Phillips v. Pennsylvania Higher Education Assistance Agencygreen | 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. Wanda A.
green
2 sentences2015In re Charles A., 367 Ill. 2015In re Charles A., 367 Ill. | 3 | 2015–2015 |
Boddie v. Connecticut
green
2 sentences2025Williams, 139 Ill. 2d at 45 (quoting Boddie, 401 U.S. at 376 ). - 16 - ¶ 46 Following this court’s precedent in Williams, 139 Ill. 2d at 28, 63 , and the Mathews factors (Mathews v. Eldridge, 424 U.S. 319, 333 (1976)) applied there, I would conclude that the Cook/Sangamon County venue statute in this case is arbitrary and unreasonable, effectively deprives plaintiff of its right to meaningful access to the legal process, and violates due process. 2025Williams, 139 Ill. 2d at 45 (quoting Boddie, 401 U.S. at 376 ). - 16 - ¶ 46 Following this court’s precedent in Williams, 139 Ill. 2d at 28, 63 , and the Mathews factors (Mathews v. Eldridge, 424 U.S. 319, 333 (1976)) applied there, I would conclude that the Cook/Sangamon County venue statute in this case is arbitrary and unreasonable, effectively deprives plaintiff of its right to meaningful access to the legal process, and violates due process. | 2 | 1990–2025 |
In Re Bernice B.
green
2 sentences2015App. 3d 399, 402 (2000) (same). ¶ 48 This court has twice considered the issue of whether termination of parental rights without a fitness hearing violates a parent’s due process rights, applying the Mathews factors each time, and has concluded that the parent’s due process rights were not violated by the lack of a fitness hearing. 1 First, in In re Bernice B., we considered the narrow question of “whether due process requires fitness to stand trial hearings for parents in termination trials who fail to cooperate with the fitness evaluation process.” In re Bernice B., 352 Ill. 2015App. 3d 399, 402 (2000) (same). ¶ 48 This court has twice considered the issue of whether termination of parental rights without a fitness hearing violates a parent’s due process rights, applying the Mathews factors each time, and has concluded that the parent’s due process rights were not violated by the lack of a fitness hearing. 1 First, in In re Bernice B., we considered the narrow question of “whether due process requires fitness to stand trial hearings for parents in termination trials who fail to cooperate with the fitness evaluation process.” In re Bernice B., 352 Ill. | 2 | 2015–2015 |
In Re Commitment of Branch
green
2 sentences2011If the State chooses to proceed against a Ryce Act respondent based on hearsay reports of prior bad acts that did not result in prosecution or conviction to establish an element of its case, the State may do so only when the respondent is competent to challenge that evidence.” Branch, 890 So. 2d at 329 . ¶ 65 Respondents argue that the above cases from foreign jurisdictions did not apply the Mathews factors and so “carry no persuasive weight.” We disagree. 2011If the State chooses to proceed against a Ryce Act respondent based on hearsay reports of prior bad acts that did not result in prosecution or conviction to establish an element of its case, the State may do so only when the respondent is competent to challenge that evidence.” Branch, 890 So. 2d at 329 . ¶ 65 Respondents argue that the above cases from foreign jurisdictions did not apply the Mathews factors and so “carry no persuasive weight.” We disagree. | 2 | 2011–2011 |
Commonwealth v. Nieves
green
2 sentences2011Nieves, 846 N.E.2d at 386 . ¶ 67 The second case applying the Mathews factors is the Supreme Court of California’s recent decision in Moore. 2011Nieves, 846 N.E.2d at 386 . ¶ 67 The second case applying the Mathews factors is the Supreme Court of California’s recent decision in Moore. | 2 | 2011–2011 |
Moore v. Superior Court
green
2 sentences2011In Moore , the California court applied its version of the due process analysis, consisting of the three Mathews factors plus a fourth factor considering "the dignitary interest in informing individuals of the nature, grounds, and consequences of the action and in enabling them to present their side of the story before a responsible government official." Moore, 114 Cal.Rptr.3d 199 , 237 P.3d at 539 . 2011In Moore, the California court applied its version of the due process analysis, consisting of the three Mathews factors plus a fourth factor considering “the dignitary interest in informing individuals of the nature, grounds, and consequences of the action and in enabling them to present their side of the story before a responsible government official.” Moore, 237 P.3d at 539 . | 2 | 2011–2011 |
People v. Sandham
green
2 sentences2004Respondent cites two delinquency cases and a criminal case to support his contention that the dictates of due process required the trial court to conduct a fitness for trial hearing: In re T.D.W., 109 Ill.App.3d 852 , 65 Ill.Dec. 363 , 441 N.E.2d 155 (1982), In re E.V., 190 Ill.App.3d 1079 , 138 Ill.Dec. 354 , 547 N.E.2d 521 (1989), *789 and People v. Sandham, 174 Ill.2d 379 , 220 Ill.Dec. 611 , 673 N.E.2d 1032 (1996). 2004Respondent cites two delinquency cases and a criminal case to support his contention that the dictates of due process required the trial court to conduct a fitness for trial hearing: In re T.D.W., 109 Ill.App.3d 852 , 65 Ill.Dec. 363 , 441 N.E.2d 155 (1982), In re E.V., 190 Ill.App.3d 1079 , 138 Ill.Dec. 354 , 547 N.E.2d 521 (1989), *789 and People v. Sandham, 174 Ill.2d 379 , 220 Ill.Dec. 611 , 673 N.E.2d 1032 (1996). | 2 | 2004–2004 |
Lyon v. Department of Children & Family Services
green
2 sentences2004In light of the Mathews factors, the court explained, “The credible-evidence standard is fair only if the alleged perpetrator soon receives a hearing under the preponderance-of-the-evidence standard and, soon after the hearing, the Department issues a final decision.” 335 Ill. 2004In light of the Mathews factors, the court explained, “The credible-evidence standard is fair only if the alleged perpetrator soon receives a hearing under the preponderance-of-the-evidence standard and, soon after the hearing, the Department issues a final decision.” 335 Ill. | 2 | 2004–2004 |
| People v. Lindsey green | 1 | 2021–2021 |
| In re J.M. green | 1 | 2021–2021 |
| Mullane v. Central Hanover Bank & Trust Co. green | 1 | 2018–2018 |
| Jones v. Flowers green | 1 | 2018–2018 |
| Cross v. City of Chicago neutral | 1 | 2015–2015 |
| People Ex Rel. Birkett v. Konetski green | 1 | 2013–2013 |
| Stillo v. State Retirement Systems green | 1 | 2009–2009 |
| United States v. David Earl Wattleton green | 1 | 2004–2004 |
| People v. T. D. W. neutral | 1 | 2004–2004 |
| People v. E.V. neutral | 1 | 2004–2004 |
| Mapes v. Hulcher green | 1 | 1990–1990 |
| Chappelle v. Sorenson green | 1 | 1990–1990 |
| Fuentes v. Shevin green | 1 | 1979–1979 |
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.