State to prove exception (Illinois) · Go Syfert
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State to prove exception in Illinois

7 Illinois opinions name it 1 courts 1973–2023 1 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
Smith v. United Statesgreen
scotus · 2013 · cited in 3 Illinois opinions naming this issue, 2015–2016
2 sentences

2016See Smith v. United States, 568 U.S. ___ , ___, 133 S. Ct. 714, 719 (2013) (while the government must prove beyond a reasonable doubt every fact necessary to constitute the crime with which the defendant is charged, the government has no constitutional duty to overcome an affirmative defense beyond a reasonable doubt). ¶ 38 Defendant is receiving a windfall in this case, which, as the dissent correctly states, is “offensive to a legal system that should uphold the rule of law over procedural sleight of hand” (infra ¶ 59), and which runs counter to the purpose of the statute of limitations.

2015See Smith v. United States, 568 U.S. ___ , ___, 133 S. Ct. 714, 719 (2013) (while the government must prove beyond a reasonable - 14 - 2015 IL App (2d) 140139 doubt every fact necessary to constitute the crime with which the defendant is charged, the government has no constitutional duty to overcome an affirmative defense beyond a reasonable doubt). ¶ 38 Defendant is receiving a windfall in this case, which, as the dissent correctly states, is “offensive to a legal system that should uphold the rule of law over procedural sleight of hand” (infra ¶ 59), and which runs counter to the purpose of

33
People v. Luttergreen
illappct · 2015 · cited in 2 Illinois opinions naming this issue, 2015–2015
2 sentences

2015See Smith v. United States, 568 U.S. ___ , ___, 133 S. Ct. 714, 719 (2013) (while the government must prove beyond a reasonable - 14 - 2015 IL App (2d) 140139 doubt every fact necessary to constitute the crime with which the defendant is charged, the government has no constitutional duty to overcome an affirmative defense beyond a reasonable doubt). ¶ 38 Defendant is receiving a windfall in this case, which, as the dissent correctly states, is “offensive to a legal system that should uphold the rule of law over procedural sleight of hand” (infra ¶ 59), and which runs counter to the purpose of

2015See Smith v. United States, 568 U.S. ___ , ___, 133 S. Ct. 714, 719 (2013) (while the government must prove beyond a reasonable - 14 - 2015 IL App (2d) 140139 doubt every fact necessary to constitute the crime with which the defendant is charged, the government has no constitutional duty to overcome an affirmative defense beyond a reasonable doubt). ¶ 38 Defendant is receiving a windfall in this case, which, as the dissent correctly states, is “offensive to a legal system that should uphold the rule of law over procedural sleight of hand” (infra ¶ 59), and which runs counter to the purpose of

22
People v. Gillgreen
illappct · 2018 · cited in 1 Illinois opinions naming this issue, 2023–2023
1 sentence

2023People v. Gill, 2018 IL App (3d) 150594, ¶ 98 (citing Chimel v. California, 395 U.S. 752, 762 (1969)). ¶ 39 The State relies on two exceptions: (1) inventory searches of lawfully impounded vehicles conducted per standard police procedure (South Dakota v. Opperman, 428 U.S. 364 (1976)), and (2) searches of automobiles when an officer has probable cause to believe the automobile may contain contraband or evidence of a crime (Carroll v. United States, 267 U.S. 132 (1925)). ¶ 40 C.

11
Chimel v. Californiared
scotus · 1969 · cited in 1 Illinois opinions naming this issue, 2023–2023
1 sentence

2023People v. Gill, 2018 IL App (3d) 150594, ¶ 98 (citing Chimel v. California, 395 U.S. 752, 762 (1969)). ¶ 39 The State relies on two exceptions: (1) inventory searches of lawfully impounded vehicles conducted per standard police procedure (South Dakota v. Opperman, 428 U.S. 364 (1976)), and (2) searches of automobiles when an officer has probable cause to believe the automobile may contain contraband or evidence of a crime (Carroll v. United States, 267 U.S. 132 (1925)). ¶ 40 C.

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 (5)

CaseCitedYears
Carroll v. United States green
scotus · 1925
1 sentence

2023People v. Gill, 2018 IL App (3d) 150594, ¶ 98 (citing Chimel v. California, 395 U.S. 752, 762 (1969)). ¶ 39 The State relies on two exceptions: (1) inventory searches of lawfully impounded vehicles conducted per standard police procedure (South Dakota v. Opperman, 428 U.S. 364 (1976)), and (2) searches of automobiles when an officer has probable cause to believe the automobile may contain contraband or evidence of a crime (Carroll v. United States, 267 U.S. 132 (1925)). ¶ 40 C.

12023–2023
South Dakota v. Opperman green
scotus · 1976
1 sentence

2023People v. Gill, 2018 IL App (3d) 150594, ¶ 98 (citing Chimel v. California, 395 U.S. 752, 762 (1969)). ¶ 39 The State relies on two exceptions: (1) inventory searches of lawfully impounded vehicles conducted per standard police procedure (South Dakota v. Opperman, 428 U.S. 364 (1976)), and (2) searches of automobiles when an officer has probable cause to believe the automobile may contain contraband or evidence of a crime (Carroll v. United States, 267 U.S. 132 (1925)). ¶ 40 C.

12023–2023
People v. McDonald green
ill · 1995
2 sentences

2009McDonald, 168 Ill. 2d at 460 , 660 N.E.2d at 849 .

2009McDonald, 168 Ill. 2d at 460 , 660 N.E.2d at 849 .

12009–2009
Schneckloth v. Bustamonte green
scotus · 1973
2 sentences

1994However, the United States Supreme Court, in Schneckloth v. Bustamonte (1973), 412 U.S. 218 , 36 L.

1994However, the United States Supreme Court, in Schneckloth v. Bustamonte (1973), 412 U.S. 218 , 36 L.

11994–1994
People v. Evans green
illappct · 1972
2 sentences

1973In People v. Evans (1972), 3 Ill.App.3d 435 , 278 N.E.2d 401 , this court held, in answer to the contention of counsel therein, that these admonishments as prescribed by Supreme Court Rule 402 (Ill.

1973In People v. Evans (1972), 3 Ill.App.3d 435 , 278 N.E.2d 401 , this court held, in answer to the contention of counsel therein, that these admonishments as prescribed by Supreme Court Rule 402 (Ill.

11973–1973

Statutes the citing opinions construe

IL § 625 ILCS 5/11-402 (3) IL § 625 ILCS 5/11-501 (3) IL § 720 ILCS 5/12-5 (3) IL § 720 ILCS 5/24-3.1 (3) IL § 720 ILCS 5/3-6 (3) IL § 725 ILCS 5/114-1 (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

AR 39 (1984–2026) IN 16 (1989–2019) TX 14 (1975–2025) WI 10 (2006–2024) WA 9 (1985–2021) CT 8 (1970–1994) FL 8 (1981–2020) IL 7 (1973–2023) WV 5 (1982–2016) OH 4 (2005–2021) GA 4 (1913–2012) SD 3 (1982–2009) TN 2 (2001–2002) UT 2 (1985–2014) MT 2 (2010–2010) MD 2 (1988–1992)

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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