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7 Illinois opinions name it 1 courts 1997–2026 3 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. Clarkgreen2 sentences2026Clark, 2023 IL 127273, ¶¶ 87, 88 . - 12 - No. 1-24-0760 ¶ 43 This court similarly recognized in Buford that nearly all of the cases that the defendant cited in support of his Miller-based claim that “his de facto life sentence violates the proportionate penalties clause because his brain was akin to that of a juvenile when he committed the offenses at age 22,” were “advanced by defendants who were 18 or 19 years old at the time they committed the offenses, rather than 22 years old.” Buford, 2023 IL App (1st) 201176, ¶ 45 . 2026By that time, the relevant proportionate penalties legal landscape was largely shaped by People v. Clark, 2023 IL 127273 , People v. Buford, 2023 IL App (1st) 201176 , and Hilliard, 2023 IL 128186 , none of which would provide Savage—an adult subject to a discretionary sentence—with relief on a Miller-based proportionate penalties clause claim. ¶ 42 In Clark, after observing that it had not barred young adult defendants of 18 or 19 from “raising as-applied proportionate penalties clause challenges to life sentences based on the evolving science on juvenile maturity and brain development,” our | 1 | 1 |
First Capitol Mortgage Corp. v. Talandis Construction Corp.green1 sentence2024McHenry Township v. McHenry County, 2022 IL 127258, ¶ 48 (citing First Capitol Mortgage Corp. v. Talandis Construction Corp., 63 Ill. 2d 128, 133 (1976)). 1 Clark also alleged she was not served with summons. | 1 | 1 |
McHenry Township v. County of McHenrygreen1 sentence2024McHenry Township v. McHenry County, 2022 IL 127258, ¶ 48 (citing First Capitol Mortgage Corp. v. Talandis Construction Corp., 63 Ill. 2d 128, 133 (1976)). 1 Clark also alleged she was not served with summons. | 1 | 1 |
People v. Williamsgreen2 sentences2013See Clark, 52 Ill. 2d at 389 ; see also Williams, 147 Ill. 2d 173 ; Antczak, 251 Ill. 2013See Clark, 52 Ill. 2d at 389 ; see also Williams, 147 Ill. 2d 173 ; Antczak, 251 Ill. | 1 | 1 |
People v. Clarkgreen2 sentences2013See Clark, 52 Ill. 2d at 389 ; see also Williams, 147 Ill. 2d 173 ; Antczak, 251 Ill. 2013See Clark, 52 Ill. 2d at 389 ; see also Williams, 147 Ill. 2d 173 ; Antczak, 251 Ill. | 1 | 1 |
Brummett v. Wepfer Marine, Inc.green1 sentence2003See Brummett, 111 Ill. 2d at 501 . | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Illinois. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
O'Loughlin v. Servicemaster Co. Limited Partnership
green
2 sentences1997O'Loughlin , 216 Ill. 1997O'Loughlin , 216 Ill. | 2 | 1997–1997 |
People v. Buford
green
2 sentences2026By that time, the relevant proportionate penalties legal landscape was largely shaped by People v. Clark, 2023 IL 127273 , People v. Buford, 2023 IL App (1st) 201176 , and Hilliard, 2023 IL 128186 , none of which would provide Savage—an adult subject to a discretionary sentence—with relief on a Miller-based proportionate penalties clause claim. ¶ 42 In Clark, after observing that it had not barred young adult defendants of 18 or 19 from “raising as-applied proportionate penalties clause challenges to life sentences based on the evolving science on juvenile maturity and brain development,” our 2026Clark, 2023 IL 127273, ¶¶ 87, 88 . - 12 - No. 1-24-0760 ¶ 43 This court similarly recognized in Buford that nearly all of the cases that the defendant cited in support of his Miller-based claim that “his de facto life sentence violates the proportionate penalties clause because his brain was akin to that of a juvenile when he committed the offenses at age 22,” were “advanced by defendants who were 18 or 19 years old at the time they committed the offenses, rather than 22 years old.” Buford, 2023 IL App (1st) 201176, ¶ 45 . | 1 | 2026–2026 |
People v. Hilliard
green
1 sentence2026By that time, the relevant proportionate penalties legal landscape was largely shaped by People v. Clark, 2023 IL 127273 , People v. Buford, 2023 IL App (1st) 201176 , and Hilliard, 2023 IL 128186 , none of which would provide Savage—an adult subject to a discretionary sentence—with relief on a Miller-based proportionate penalties clause claim. ¶ 42 In Clark, after observing that it had not barred young adult defendants of 18 or 19 from “raising as-applied proportionate penalties clause challenges to life sentences based on the evolving science on juvenile maturity and brain development,” our | 1 | 2026–2026 |
Williams v. Athletico, Ltd
green
1 sentence2023Williams v. Athletico, Ltd., 2017 IL App (1st) 161902, ¶ 11 . ¶8 A plaintiff must file a section 2-622 affidavit supported by a health professional’s written report where a plaintiff seeks damages for injuries caused “by reason of medical, hospital, or other healing art malpractice.” (Emphasis added.) 735 ILCS 5/2-622(a). | 1 | 2023–2023 |
People v. Cuadrado
green
1 sentence2013In Cuadrado, referring to admissibility of prior consistent statements, the supreme court stated that they are admissible “when it is suggested that the witness had recently fabricated the testimony or had a motive to testify falsely, and the prior statement was made before the motive to fabricate arose.” Id. at 90 . ¶ 57 The author picks Clark out of a lineup of supreme court cases on the issue and, through a misreading of Clark and other supreme court cases, creates what he calls the “Clark rule.” Supra ¶ 32. | 1 | 2013–2013 |
People v. Antczak
green
2 sentences2013See Clark, 52 Ill. 2d at 389 ; see also Williams, 147 Ill. 2d 173 ; Antczak, 251 Ill. 2013See Clark, 52 Ill. 2d at 389 ; see also Williams, 147 Ill. 2d 173 ; Antczak, 251 Ill. | 1 | 2013–2013 |
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.