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6 Illinois opinions name it 2 courts 2019–2025 4 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. Wricegreen1 sentence2025See Wrice, 2012 IL 111860, ¶ 84 (“use of a defendant’s physically coerced confession as substantive evidence of his guilt is never harmless error”). | 1 | 1 |
People v. Colemangreen2 sentences2023See Anderson, 2023 IL App (1st) 200462, ¶ 175 (discussing People v. Whirl, 2015 IL App (1st) 111483, ¶ 113 (“Whirl confirms that it is error for the court to focus on defendant’s credibility, instead of assessing whether the new evidence would likely have altered the result of the suppression hearing. [Citation.] Nevertheless, Whirl indicates that this error does not end our review where, as here, the trial court also made specific findings regarding the new evidence offered to show a ‘pattern and practice’ of abuse and coercion.”) See also Nelson, 235 Ill. 2d at 421-22 (lawsuit must have some 2023See Anderson, 2023 IL App (1st) 200462, ¶ 175 (discussing People v. Whirl, 2015 IL App (1st) 111483, ¶ 113 (“Whirl confirms that it is error for the court to focus on defendant’s credibility, instead of assessing whether the new evidence would likely have altered the result of the suppression hearing. [Citation.] Nevertheless, Whirl indicates that this error does not end our review where, as here, the trial court also made specific findings regarding the new evidence offered to show a ‘pattern and practice’ of abuse and coercion.”) See also Nelson, 235 Ill. 2d at 421-22 (lawsuit must have some | 1 | 1 |
People v. Nelsongreen1 sentence2023See Anderson, 2023 IL App (1st) 200462, ¶ 175 (discussing People v. Whirl, 2015 IL App (1st) 111483, ¶ 113 (“Whirl confirms that it is error for the court to focus on defendant’s credibility, instead of assessing whether the new evidence would likely have altered the result of the suppression hearing. [Citation.] Nevertheless, Whirl indicates that this error does not end our review where, as here, the trial court also made specific findings regarding the new evidence offered to show a ‘pattern and practice’ of abuse and coercion.”) See also Nelson, 235 Ill. 2d at 421-22 (lawsuit must have some | 1 | 1 |
People v. Andersongreen1 sentence2023See Anderson, 2023 IL App (1st) 200462, ¶ 175 (discussing People v. Whirl, 2015 IL App (1st) 111483, ¶ 113 (“Whirl confirms that it is error for the court to focus on defendant’s credibility, instead of assessing whether the new evidence would likely have altered the result of the suppression hearing. [Citation.] Nevertheless, Whirl indicates that this error does not end our review where, as here, the trial court also made specific findings regarding the new evidence offered to show a ‘pattern and practice’ of abuse and coercion.”) See also Nelson, 235 Ill. 2d at 421-22 (lawsuit must have some | 1 | 1 |
People v. Myersgreen1 sentence2023See Anderson, 2023 IL App (1st) 200462, ¶ 175 (discussing People v. Whirl, 2015 IL App (1st) 111483, ¶ 113 (“Whirl confirms that it is error for the court to focus on defendant’s credibility, instead of assessing whether the new evidence would likely have altered the result of the suppression hearing. [Citation.] Nevertheless, Whirl indicates that this error does not end our review where, as here, the trial court also made specific findings regarding the new evidence offered to show a ‘pattern and practice’ of abuse and coercion.”) See also Nelson, 235 Ill. 2d at 421-22 (lawsuit must have some | 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. Urdiales
green
1 sentence2025Thus, a petitioner must establish that, based on the totality of the circumstances, it is more likely than not that the result of the suppression hearing would have been different had the new evidence been admitted, making the introduction of the confession at trial a violation of his constitutional rights.” Id. | 1 | 2025–2025 |
People v. Christian
green
1 sentence2022The State, citing People v. Christian, 2016 IL App (1st) 140030 , argued that defendant was required to prove he was tortured, whereas defendant, relying on People v. Whirl, 2015 IL App (1st) 111483 , argued that he need only show that the result of the suppression hearing would have been different had the interrogating officers been impeached with new evidence suggesting they exhibited a pattern of abusive tactics. | 1 | 2022–2022 |
People v. Gacy
green
1 sentence2020Gacy, 125 Ill. 2d at 126 . | 1 | 2020–2020 |
People v. Patterson
green
1 sentence2019The court concluded that after reviewing the evidence it could not “conclude that [the] defendant [had] demonstrated that, had [his attorney] interviewed these witnesses, a reasonable probability exists that the result of the suppression hearing would have been different.” Id. ¶ 79 The defendant in Patterson also argued that his attorney erred in failing to inform the trial court of the similarities between his torture allegations and another defendant who had raised similar torture allegations, both involving Jon Burge. | 1 | 2019–2019 |
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.