Summers rule in Illinois

7 Illinois opinions name it 2 courts 1986–2012 0 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)

Case	Followed	Cited
United States v. Joe W. Fountain (92-1507) Carlton B. McEaddy (92-1866)green ca6 · 1993 · cited in 2 Illinois opinions naming this issue, 2005–2005 2 sentences 2005See also Bohannon , 225 F.3d at 616-17 (explaining that many of the rationales underlying Summers , the prevention of flight if incriminating evidence was found and the minimization of risk of harm to the officers, were also present in the detention of nonresidents); Fountain , 2 F.3d at 662-64 (applying the Summers analysis in holding that Summers includes nonresidents of the searched premises). 2005See also Bohannon , 225 F.3d at 616-17 (explaining that many of the rationales underlying Summers , the prevention of flight if incriminating evidence was found and the minimization of risk of harm to the officers, were also present in the detention of nonresidents); Fountain , 2 F.3d at 662-64 (applying the Summers analysis in holding that Summers includes nonresidents of the searched premises).	2	2
United States v. James M. Bohannongreen ca6 · 2000 · cited in 2 Illinois opinions naming this issue, 2005–2005 2 sentences 2005See also Bohannon , 225 F.3d at 616-17 (explaining that many of the rationales underlying Summers , the prevention of flight if incriminating evidence was found and the minimization of risk of harm to the officers, were also present in the detention of nonresidents); Fountain , 2 F.3d at 662-64 (applying the Summers analysis in holding that Summers includes nonresidents of the searched premises). 2005See also Bohannon , 225 F.3d at 616-17 (explaining that many of the rationales underlying Summers , the prevention of flight if incriminating evidence was found and the minimization of risk of harm to the officers, were also present in the detention of nonresidents); Fountain , 2 F.3d at 662-64 (applying the Summers analysis in holding that Summers includes nonresidents of the searched premises).	2	2
United States v. Baileygreen ca2 · 2011 · cited in 1 Illinois opinions naming this issue, 2012–2012 2 sentences 2012Instead, we hold today that Summers authorizes law enforcement to detain the occupant of premises subject to a valid search warrant when that person is seen leaving those premises and the detention is effected as soon as reasonably practicable.” (Emphasis in original.) United States v. Bailey, 652 F.3d 197, 208 (2d Cir. 2011). 2012Instead, we hold today that Summers authorizes law enforcement to detain the occupant of premises subject to a valid search warrant when that person is seen leaving those premises and the detention is effected as soon as reasonably practicable.” (Emphasis in original.) United States v. Bailey, 652 F.3d 197, 208 (2d Cir. 2011).	1	1
People v. Whitegreen ill · 2011 · cited in 1 Illinois opinions naming this issue, 2011–2011 2 sentences 2011Supra ¶ 27, 352 Ill.Dec. at 165-66, 953 N.E.2d at 404-05. ¶ 40 People v. Keller, 353 Ill.App.3d 830 , 289 Ill.Dec. 405 , 819 N.E.2d 1205 (2004), is more illuminating. 2011Supra ¶ 27, 352 Ill.Dec. at 165-66, 953 N.E.2d at 404-05. ¶ 40 People v. Keller, 353 Ill.App.3d 830 , 289 Ill.Dec. 405 , 819 N.E.2d 1205 (2004), is more illuminating.	1	1

Distinguished, questioned or overruled (0)

Case	Negative	Cited
No negative-treatment citations attached to this issue in Illinois. Read the followed side critically anyway.

Also cited on this issue (5)

Case	Cited	Years
People v. Keller green illappct · 2004 2 sentences 2011Supra ¶ 27, 352 Ill.Dec. at 165-66, 953 N.E.2d at 404-05. ¶ 40 People v. Keller, 353 Ill.App.3d 830 , 289 Ill.Dec. 405 , 819 N.E.2d 1205 (2004), is more illuminating. 2011Supra ¶ 27, 352 Ill.Dec. at 165-66, 953 N.E.2d at 404-05. ¶ 40 People v. Keller, 353 Ill.App.3d 830 , 289 Ill.Dec. 405 , 819 N.E.2d 1205 (2004), is more illuminating.	2	2011–2011
Sindell v. Abbott Laboratories green cal · 1980 2 sentences 1988The Restatement comments that modification of the Summers rule may be necessary in a situation like that before us *.” 12 26 Cal. 3d at 610 , 607 P.2d at 936 , 163 Cal. Rptr. at 144 . 1988The Restatement comments that modification of the Summers rule may be necessary in a situation like that before us *.” 12 26 Cal. 3d at 610 , 607 P.2d at 936 , 163 Cal. Rptr. at 144 .	1	1988–1988
Summers v. Tice green cal · 1948 2 sentences 1988Summers v. Tice (1948), 33 Cal. 2d 80, 86-88 , 199 P.2d 1 . 4-5. 12 The Summers rule has generally been limited to eases where all of the potential wrongdoers were joined as defendants and where the wrongdoers’ actions occurred simultaneously and created substantially the same risk. 1988Summers v. Tice (1948), 33 Cal. 2d 80, 86-88 , 199 P.2d 1 . 4-5. 12 The Summers rule has generally been limited to eases where all of the potential wrongdoers were joined as defendants and where the wrongdoers’ actions occurred simultaneously and created substantially the same risk.	1	1988–1988
People v. Bailey green illappct · 1985 1 sentence 1986(See People v. Bailey (1985), 132 Ill.	1	1986–1986
David v. United States green scotus · 1971 1 sentence 1986Ed. 2d 136 , 91 S. Ct. 1657 ), and there is no proof here that Summers’ plea was coerced in order to dissuade him from testifying on defendant’s behalf.	1	1986–1986

Where else courts name it

IL 7 (1986–2012) NC 6 (2018–2022) IN 6 (1990–2016) CA 5 (1981–1996) NM 4 (1989–2025) PA 4 (1994–2018) WA 4 (2002–2024) OK 3 (1994–2019) MN 2 (1994–1999) AZ 2 (1996–2015) GA 2 (2000–2015) NJ 2 (2020–2023) KS 2 (2000–2013)

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.

← Caselaw search · G Cite Topics · Brief Check