deferential manifest-weight standard (Illinois) · Go Syfert
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deferential manifest-weight standard in Illinois

8 Illinois opinions name it 1 courts 2020–2026 7 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 (4)

CaseFollowedCited
Ornelas v. United Statesgreen
scotus · 1996 · cited in 2 Illinois opinions naming this issue, 2023–2025
2 sentences

2025Ornelas v. United States, 517 U.S. 690, 696, 699 (1996); In re G.O., 191 Ill. 2d 37, 49-50 (2000); Braggs, 209 Ill. 2d at 505 ; - 26 - Leanos, 2023 IL App (1st) 191079, ¶¶ 30-31 . ¶ 95 The circumstances of defendant’s interrogation are largely undisputed.

2023Braggs, 209 Ill. 2d at 505 . ¶ 29 Suppression motions generally present “mixed questions of law and fact,” to which we apply the bifurcated standard of review established in Ornelas v. United States, 517 U.S. 690 (1996), and first adopted by our supreme court in In re G.O., 191 Ill. 2d 37 (2000). ¶ 30 We review the trial court’s findings of “historical fact” under the deferential manifest- weight standard.

22
In re Marriage of Arjmandgreen
illappct · 2013 · cited in 1 Illinois opinions naming this issue, 2026–2026
1 sentence

2026See In re Marriage of Arjmand, 2013 IL App (2d) 120639, ¶ 32 .

11
People v. Dunmiregreen
illappct · 2021 · cited in 1 Illinois opinions naming this issue, 2022–2022
1 sentence

2022People v. Dunmire, 2019 IL App (4th) 190316, ¶ 35 (manifest-weight review of suppression ruling means we will reverse if “ ‘the opposite conclusion is clearly evident or if the finding itself is unreasonable, arbitrary, or not based on the evidence presented’ ” (quoting People v. Peterson, 2017 IL 120331, ¶ 39 )). ¶ 84 Second and more to the point, I must respectfully disagree with my dissenting colleague that his interpretation of this exchange is reasonable.

11
Hale v. FIRST NAT'L BK. OF MT. PROSPECTgreen
illappct · 1978 · cited in 1 Illinois opinions naming this issue, 2021–2021
1 sentence

2021See Hale v. First National Bank of Mount Prospect, 57 Ill.

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 (3)

CaseCitedYears
People v. Leanos green
illappct · 2023
2 sentences

2024We review the trial court’s findings of ‘historical fact’ under the deferential manifest-weight standard. *** But we review de novo the trial court’s determination regarding the ultimate ground for suppression raised in the motion.” People v. Leanos, 2023 IL App (1st) 191079, ¶¶ 29-31 . ¶ 29 In pertinent part, defendant argues that he did not knowingly waive his Miranda rights and his statement to police was not voluntary because police lied to him and told him that anything he said would stay between them.

2024We agree with defendant and find defendant’s waiver of his Miranda rights was not voluntary (or, more specifically, that the voluntariness of his waiver was overborne), requiring suppression of defendant’s inculpatory statements to police. 1 “Suppression motions generally present ‘mixed questions of law and fact,’ to which we apply [a] bifurcated standard of review ***. [Citations.] We review the trial court’s findings of ‘historical fact’ under the deferential manifest-weight standard. [Citations.] But we review de novo the trial court’s determination regarding the ultimate ground for suppres

32024–2025
People v. Braggs green
ill · 2004
2 sentences

2025Ornelas v. United States, 517 U.S. 690, 696, 699 (1996); In re G.O., 191 Ill. 2d 37, 49-50 (2000); Braggs, 209 Ill. 2d at 505 ; - 26 - Leanos, 2023 IL App (1st) 191079, ¶¶ 30-31 . ¶ 95 The circumstances of defendant’s interrogation are largely undisputed.

2023Braggs, 209 Ill. 2d at 505 . ¶ 29 Suppression motions generally present “mixed questions of law and fact,” to which we apply the bifurcated standard of review established in Ornelas v. United States, 517 U.S. 690 (1996), and first adopted by our supreme court in In re G.O., 191 Ill. 2d 37 (2000). ¶ 30 We review the trial court’s findings of “historical fact” under the deferential manifest- weight standard.

22023–2025
Eychaner v. Gross green
ill · 2002
1 sentence

2020The dismissal of complaint is reviewed de novo (id. at 1045), while this court must employ the more deferential manifest weight standard (Eychaner, 202 Ill. 2d at 251 ).

12020–2020

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