burden defense (Illinois) · Go Syfert
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burden defense in Illinois

53 Illinois opinions name it 2 courts 1915–2025 6 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 (18)

CaseFollowedCited
Sandholm v. Kueckergreen
ill · 2012 · cited in 2 Illinois opinions naming this issue, 2014–2014
2 sentences

2014Sandholm reformulated the movant’s burden under the test in the following terms: “In light of the clear legislative intent expressed in the statute to subject only meritless, retaliatory SLAPP suits to dismissal, we construe the phrase ‘based on, relates to, or is in response to’ in section 15 to mean solely based on, relating to, or in response to ‘any act or acts of the moving party in furtherance of the moving party’s rights of petition, speech, association, or to otherwise participate in government.’ ” (Emphasis in original.) Sandholm, 2012 IL 111443, ¶ 45 (quoting 735 ILCS 110/15 (West 20

2014Sandholm reformulated the movant’s burden under the test in the following terms: “In light of the clear legislative intent expressed in the statute to subject only meritless, retaliatory SLAPP suits to dismissal, we construe the phrase ‘based on, relates to, or is in response to’ in section 15 to mean solely based on, relating to, or in response to ‘any act or acts of the moving party in furtherance of the moving party’s rights of petition, speech, association, or to otherwise participate in government.’ ” (Emphasis in original.) Sandholm, 2012 IL 111443, ¶ 45 (quoting 735 ILCS 110/15 (West 20

22
Morrison v. Flowersgreen
ill · 1923 · cited in 2 Illinois opinions naming this issue, 2012–2012
2 sentences

2012See Morrison v. Flowers, 308 Ill. 189, 195 , 139 N.E. 10 (1923) ("A prima facie case is one * * * established by evidence adduced by the plaintiff in support of his case * * *."); Getto v. City of Chicago, 392 Ill.App.3d 232, 239-40 , 332 Ill.Dec. 596 , 913 N.E.2d 528 (2009) (circuit court erred in shifting the burden of proof to the defendant at the conclusion of the trial); Tepper v. County of Lake, 233 Ill.App.3d 80, 81 , 174 Ill.Dec. 164 , 598 N.E.2d 361 (1992) (circuit court erred in granting the defendant's motion for a directed finding when the plaintiff presented a prima facie case). ¶

2012See Morrison v. Flowers, 308 Ill. 189, 195 , 139 N.E. 10 (1923) ("A prima facie case is one * * * established by evidence adduced by the plaintiff in support of his case * * *."); Getto v. City of Chicago, 392 Ill.App.3d 232, 239-40 , 332 Ill.Dec. 596 , 913 N.E.2d 528 (2009) (circuit court erred in shifting the burden of proof to the defendant at the conclusion of the trial); Tepper v. County of Lake, 233 Ill.App.3d 80, 81 , 174 Ill.Dec. 164 , 598 N.E.2d 361 (1992) (circuit court erred in granting the defendant's motion for a directed finding when the plaintiff presented a prima facie case). ¶

22
People v. Lindgreen
illappct · 1999 · cited in 2 Illinois opinions naming this issue, 2002–2002
2 sentences

2002See People v. Lind , 307 Ill.

2002See People v. Lind, 307 Ill.

22
Pontiac Lodge No. 294 v. Department of Revenuegreen
illappct · 1993 · cited in 2 Illinois opinions naming this issue, 1998–1998
2 sentences

1998See Pontiac Lodge, 243 Ill.

1998See Pontiac Lodge , 243 Ill.

22
Wilson v. Clarkgreen
ill · 1981 · cited in 2 Illinois opinions naming this issue, 2019–2019
2 sentences

2019The expert may in any event be required to disclose the underlying facts or data on cross-examination." Under Rule 705, the burden is on the defense " 'during cross-examination to elicit the facts underlying the expert opinion.' " Negron , 2012 IL App (1st) 101194 , ¶ 42, 368 Ill.Dec. 545 , 984 N.E.2d 491 (quoting Wilson v. Clark , 84 Ill. 2d 186 , 194, 417 N.E.2d 1322 , 1327, 49 Ill.Dec. 308 (1981) ).

2019The expert may in any event be required to disclose the underlying facts or data on cross-examination." Under Rule 705, the burden is on the defense " 'during cross-examination to elicit the facts underlying the expert opinion.' " Negron , 2012 IL App (1st) 101194 , ¶ 42, 368 Ill.Dec. 545 , 984 N.E.2d 491 (quoting Wilson v. Clark , 84 Ill. 2d 186 , 194, 417 N.E.2d 1322 , 1327, 49 Ill.Dec. 308 (1981) ).

12
People v. Negrongreen
illappct · 2012 · cited in 2 Illinois opinions naming this issue, 2019–2019
2 sentences

2019The expert may in any event be required to disclose the underlying facts or data on cross-examination." Under Rule 705, the burden is on the defense " 'during cross-examination to elicit the facts underlying the expert opinion.' " Negron , 2012 IL App (1st) 101194 , ¶ 42, 368 Ill.Dec. 545 , 984 N.E.2d 491 (quoting Wilson v. Clark , 84 Ill. 2d 186 , 194, 417 N.E.2d 1322 , 1327, 49 Ill.Dec. 308 (1981) ).

2019The expert may in any event be required to disclose the underlying facts or data on cross-examination." Under Rule 705, the burden is on the defense " 'during cross-examination to elicit the facts underlying the expert opinion.' " Negron , 2012 IL App (1st) 101194 , ¶ 42, 368 Ill.Dec. 545 , 984 N.E.2d 491 (quoting Wilson v. Clark , 84 Ill. 2d 186 , 194, 417 N.E.2d 1322 , 1327, 49 Ill.Dec. 308 (1981) ).

12
Getto v. City of Chicagogreen
illappct · 2009 · cited in 2 Illinois opinions naming this issue, 2012–2012
2 sentences

2012See Morrison v. Flowers, 308 Ill. 189, 195 , 139 N.E. 10 (1923) ("A prima facie case is one * * * established by evidence adduced by the plaintiff in support of his case * * *."); Getto v. City of Chicago, 392 Ill.App.3d 232, 239-40 , 332 Ill.Dec. 596 , 913 N.E.2d 528 (2009) (circuit court erred in shifting the burden of proof to the defendant at the conclusion of the trial); Tepper v. County of Lake, 233 Ill.App.3d 80, 81 , 174 Ill.Dec. 164 , 598 N.E.2d 361 (1992) (circuit court erred in granting the defendant's motion for a directed finding when the plaintiff presented a prima facie case). ¶

2012See Morrison v. Flowers, 308 Ill. 189, 195 , 139 N.E. 10 (1923) ("A prima facie case is one * * * established by evidence adduced by the plaintiff in support of his case * * *."); Getto v. City of Chicago, 392 Ill.App.3d 232, 239-40 , 332 Ill.Dec. 596 , 913 N.E.2d 528 (2009) (circuit court erred in shifting the burden of proof to the defendant at the conclusion of the trial); Tepper v. County of Lake, 233 Ill.App.3d 80, 81 , 174 Ill.Dec. 164 , 598 N.E.2d 361 (1992) (circuit court erred in granting the defendant's motion for a directed finding when the plaintiff presented a prima facie case). ¶

12
Peguero v. United Statesgreen
scotus · 1999 · cited in 2 Illinois opinions naming this issue, 2001–2001
2 sentences

2001It is irrelevant whether one characterizes this burden as a requirement to allege deficient performance or prejudice because the principle remains the same: the pro se defendant cannot be expected "`to specify the grounds for [his] appeal and show that they have some merit.'" Flores-Ortega, 528 U.S. at 486 , 120 S.Ct. at 1040 , 145 L.Ed.2d at 1001 , quoting Peguero v. United States, 526 U.S. 23, 30 , 119 S.Ct. 961, 966 , 143 L.Ed.2d 18, 25-26 (1999) (O'Connor, J., concurring, joined by Stevens, Ginsburg and Breyer, JJ.).

2001It is irrelevant whether one characterizes this burden as a requirement to allege deficient performance or prejudice because the principle remains the same: the pro se defendant cannot be expected "`to specify the grounds for [his] appeal and show that they have some merit.'" Flores-Ortega, 528 U.S. at 486 , 120 S.Ct. at 1040 , 145 L.Ed.2d at 1001 , quoting Peguero v. United States, 526 U.S. 23, 30 , 119 S.Ct. 961, 966 , 143 L.Ed.2d 18, 25-26 (1999) (O'Connor, J., concurring, joined by Stevens, Ginsburg and Breyer, JJ.).

12
People v. Devinegreen
illappct · 1998 · cited in 1 Illinois opinions naming this issue, 2025–2025
1 sentence

2025In People v. Devine, 295 Ill.

11
Maryland v. Shatzergreen
scotus · 2010 · cited in 1 Illinois opinions naming this issue, 2025–2025
1 sentence

2025Maryland v. Shatzer, 559 U.S. 98, 104 (2010); Moran v. Burbine, 475 U.S. 412, 421 (1986); People v. Braggs, 209 Ill. 2d 492, 505 (2003); 725 ILCS 5/114-11(d) (West 2024). ¶ 85 We recognize that the statute here only mentions the State’s burden to show that the minor’s statement was “voluntarily given,” without mention of “knowingly” or “intelligently.” But you cannot have a voluntary waiver without a knowing and intelligent one; you cannot make a “free and deliberate” choice to waive your rights, and thus a “voluntary” waiver (Moran, 475 - 23 - No. 1-22-1601 U.S. at 421), unless you first unde

11
People v. Braggsgreen
ill · 2004 · cited in 1 Illinois opinions naming this issue, 2025–2025
1 sentence

2025Maryland v. Shatzer, 559 U.S. 98, 104 (2010); Moran v. Burbine, 475 U.S. 412, 421 (1986); People v. Braggs, 209 Ill. 2d 492, 505 (2003); 725 ILCS 5/114-11(d) (West 2024). ¶ 85 We recognize that the statute here only mentions the State’s burden to show that the minor’s statement was “voluntarily given,” without mention of “knowingly” or “intelligently.” But you cannot have a voluntary waiver without a knowing and intelligent one; you cannot make a “free and deliberate” choice to waive your rights, and thus a “voluntary” waiver (Moran, 475 - 23 - No. 1-22-1601 U.S. at 421), unless you first unde

11
Moran v. Burbinegreen
scotus · 1986 · cited in 1 Illinois opinions naming this issue, 2025–2025
1 sentence

2025Maryland v. Shatzer, 559 U.S. 98, 104 (2010); Moran v. Burbine, 475 U.S. 412, 421 (1986); People v. Braggs, 209 Ill. 2d 492, 505 (2003); 725 ILCS 5/114-11(d) (West 2024). ¶ 85 We recognize that the statute here only mentions the State’s burden to show that the minor’s statement was “voluntarily given,” without mention of “knowingly” or “intelligently.” But you cannot have a voluntary waiver without a knowing and intelligent one; you cannot make a “free and deliberate” choice to waive your rights, and thus a “voluntary” waiver (Moran, 475 - 23 - No. 1-22-1601 U.S. at 421), unless you first unde

11
People v. Berggreen
ill · 1977 · cited in 1 Illinois opinions naming this issue, 2021–2021
1 sentence

2021People v. Brooks, 2017 IL 121413, ¶ 22 ; see People v. Berg, 67 Ill. 2d 65, 68 (1977) (“Where the basis for the motion is an allegedly illegal search, it is incumbent upon the defendant in the first instance to establish both components: that there was a search, and that it was illegal.”). ¶ 55 But we need not dwell on these failures (they are documented in enough detail above) or the issue of counsel’s deficiency.

11
In Re Marriage of Wanstreetgreen
illappct · 2006 · cited in 1 Illinois opinions naming this issue, 2020–2020
1 sentence

2020See, e.g., In re Marriage of Wanstreet, 364 Ill.

11
Texas Department of Community Affairs v. Burdinegreen
scotus · 1981 · cited in 1 Illinois opinions naming this issue, 2020–2020
1 sentence

2020Texas Department of Community Affairs v. Burdine, 450 U.S. 248, 259-60 (1981).

11
Board of Managers of Chestnut Hills Condominium Ass'n v. Pasquinelli, Inc.green
illappct · 2004 · cited in 1 Illinois opinions naming this issue, 2012–2012
11
Herlihy v. Dunbar Builders Corp.green
illappct · 1980 · cited in 1 Illinois opinions naming this issue, 2012–2012
11
Paschall v. Reedgreen
illappct · 1943 · cited in 1 Illinois opinions naming this issue, 1961–1961
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 (33)

CaseCitedYears
Petersen v. Hubschman Construction Co. green
ill · 1979
2 sentences

2012A knowing waiver of this protection will not be readily implied.’ *** [Citation.]” (Emphasis omitted.) Petersen, 76 Ill. 2d at 43 . ¶ 29 Cases subsequent to Petersen, continue to follow this high standard and hold that the burden for waiver of an implied warranty by way of a disclaimer will be met only where: “(1) [the disclaimer] is a conspicuous provision (2) which fully discloses the consequences of its inclusion (3) that was, in fact, the agreement of the parties.” Board of Managers of Chestnut Hills Condominium Ass’n v. Pasquinelli, Inc., 354 Ill.

2012Since the public policy behind the implied warranty of habitability is to protect homeowners and to construe disclaimers strictly against builders-vendors (Petersen, 76 Ill. 2d at 43 ), we see no reason why, under the plain language of the aforementioned disclaimer provision, we should attempt to circumvent the clear and unambiguous intent of the parties and extend the disclaimer to include parties other than the seller, Wayne (Thompson, 241 Ill. 2d at 441 ).

32004–2012
Badillo v. DeVivo green
illappct · 1987
2 sentences

2018Id. at 599 , 113 Ill.Dec. 696 , 515 N.E.2d 681 . ¶ 62 However, there are exceptions to the general rule that a bar owner's duty to protect its patrons from criminal acts of third parties ends at the bar's property line.

2018Id. at 599 , 113 Ill.Dec. 696 , 515 N.E.2d 681 . ¶ 62 However, there are exceptions to the general rule that a bar owner's duty to protect its patrons from criminal acts of third parties ends at the bar's property line.

22018–2018
People v. Zehr green
ill · 1984
2 sentences

2013Our decision was cast as an effort to effectuate the principles established in People v. Zehr, 103 Ill. 2d 472 (1984), and recognized that a general or broad statement of law that the burden of proof in a criminal case is beyond a reasonable doubt did not adequately inform jurors of the law when the insanity defense is raised.

2013Our decision was cast as an effort to effectuate the principles established in People v. Zehr, 103 Ill. 2d 472 (1984), and recognized that a general or broad statement of law that the burden of proof in a criminal case is beyond a reasonable doubt did not adequately inform jurors of the law when the insanity defense is raised.

22013–2013
Northern Illinois Emergency Physicians v. Landau, Omahana & Kopka, Ltd. green
ill · 2005
2 sentences

2008The plaintiff's burden in a defense-type legal malpractice case is generally addressed in Northern Illinois Emergency Physicians, 216 Ill. 2d 294 .

2008The plaintiff’s burden in a defense-type legal malpractice case is generally addressed in Northern Illinois Emergency Physicians, 216 Ill. 2d 294 .

22008–2008
Walker v. American River Transportation green
illappct · 1996
2 sentences

2002Furthermore, a "defendant seeking transfer from a forum that bears no practical connection to the litigation still shoulders the responsibility of meeting this burden under the doctrine." Walker , 277 Ill.

2002Furthermore, a “defendant seeking transfer from a forum that bears no practical connection to the litigation still shoulders the responsibility of meeting this burden under the doctrine.” Walker, 277 Ill.

22002–2002
Roe v. Flores-Ortega green
scotus · 2000
2 sentences

2001It is irrelevant whether one characterizes this burden as a requirement to allege deficient performance or prejudice because the principle remains the same: the pro se defendant cannot be expected “ ‘to specify the grounds for [his] appeal and show that they have some merit.’ ” Flores-Ortega, 528 U.S. at 486 , 145 L.

2001It is irrelevant whether one characterizes this burden as a requirement to allege deficient performance or prejudice because the principle remains the same: the pro se defendant cannot be expected “ ‘to specify the grounds for [his] appeal and show that they have some merit.’ ” Flores-Ortega, 528 U.S. at 486 , 145 L.

22001–2001
People v. Scott green
ill · 1992
2 sentences

2000This court has previously held that the provisions imposing this burden on the defense do not violate due process under the federal or state constitutions (Scott, 148 Ill. 2d at 540-43 ), and the defendant has not presented us with any reason that would warrant our reaching a different result under the eighth amendment.

2000This court has previously held that the provisions imposing this burden on the defense do not violate due process under the federal or state constitutions ( Scott, 148 Ill.2d at 540-43 , 171 Ill.Dec. 365 , 594 N.E.2d 217 ), and the defendant has not presented us with any reason that would warrant our reaching a different result under the eighth amendment.

22000–2000
In Interest of KG green
illappct · 1997
2 sentences

2000The first question in the hearing, whether or not the petition has been sustained by the evidence, my conclusion for the reasons I have indicated, the court's observations, the K.G. [ 288 Ill.App.3d 728 , 224 Ill.Dec. 534 , 682 N.E.2d 95 ] case, every case must be determined on its own facts.

2000The first question in the hearing, whether or not the petition has been sustained by the evidence, my conclusion for the reasons I have indicated, the court's observations, the K.G. [ 288 Ill.App.3d 728 , 224 Ill.Dec. 534 , 682 N.E.2d 95 ] case, every case must be determined on its own facts.

22000–2000
O'Connor v. Harris Bank Barrington, N.A. green
illappct · 1993
2 sentences

1995The petitioner bears the burden at the hearing of introducing evidence establishing reasonable grounds for removal. ( In re Estate of Kirk (1993), 242 Ill.App.3d 68, 73 , 183 Ill.Dec. 274 , 611 N.E.2d 537 .) If the petitioner meets her burden, the respondent then must prove his *778 fitness to retain office.

1995The petitioner bears the burden at the hearing of introducing evidence establishing reasonable grounds for removal. ( In re Estate of Kirk (1993), 242 Ill.App.3d 68, 73 , 183 Ill.Dec. 274 , 611 N.E.2d 537 .) If the petitioner meets her burden, the respondent then must prove his *778 fitness to retain office.

21995–1995
People v. Harris green
ill · 2025
1 sentence

2025Harris, 2025 IL 130351, ¶ 41 . - 17 - Nos. 1-22-1033, 1-22-1034, & 1-22-1035 cons. new trial?” The court found that in Mr. Harris’s original trials, the defense was “severely limited in impeaching the detectives involved in this investigation undermining the [defense’s] ability to fully and thoroughly attack the statements attributed to [Mr. Harris].” The court found that the defense was significantly and unfairly prejudiced by the lack of information of past misconduct attributed to the detectives involved in Mr. Harris’s interrogation, and new trials would allow the trier of fact to consider

12025–2025
State v. Mikusch green
ill · 1990
1 sentence

2025This presumption of inadmissibility “may be overcome by a preponderance of the evidence that the statement was voluntarily given and is reliable, based on the totality of the circumstances.” Id. § 103-2.1(f). ¶ 84 This framework, with one exception we will mention below, is little more than a restatement of the State’s burden on a claim of a garden-variety Miranda violation, where the State must show that the defendant’s decision to waive his rights and speak to the police was voluntarily, knowingly, and intelligently made.

12025–2025
People v. Perez green
illappct · 2024
1 sentence

2024However, we need not address this argument because the record clearly shows that the court did not rely on this basis for revoking defendant’s release. - 11 - No. 1-24-0211B the denial of pretrial release under section 110-6.1 of the Code, not a revocation hearing under section 110-6(a). 725 ILCS 5/110-6.1; Perez, 2024 IL App (2d) 230504, ¶ 15 .

12024–2024
People v. Hughes green
ill · 2013
1 sentence

2024Hughes, 2012 IL 112817, ¶ 58 . 11 that defendant reasonably relied on that advice in making the decisions to plead guilty, means that counsel was ineffective.

12024–2024
People v. Brooks green
ill · 2017
1 sentence

2021People v. Brooks, 2017 IL 121413, ¶ 22 ; see People v. Berg, 67 Ill. 2d 65, 68 (1977) (“Where the basis for the motion is an allegedly illegal search, it is incumbent upon the defendant in the first instance to establish both components: that there was a search, and that it was illegal.”). ¶ 55 But we need not dwell on these failures (they are documented in enough detail above) or the issue of counsel’s deficiency.

12021–2021
People v. Clark green
illappct · 2015
1 sentence

2019For example, in People v. Clark, 2015 IL App (3d) 140036, ¶ 24 , the appellate court took the defendant to task for failing to offer evidence that the gun was fake or some type of air rifle.

12019–2019
People v. Knight green
illappct · 2001
12014–2014
Thompson v. Gordon green
ill · 2011
12012–2012
Tepper v. County of Lake green
illappct · 1992
12012–2012
People v. $1,124,905 U.S. Currency green
ill · 1997
12007–2007
Griffith v. Mitsubishi Aircraft International, Inc. green
ill · 1990
11996–1996
Powell v. Western Illinois Electric Cooperative green
illappct · 1989
11995–1995
People v. Fierer green
ill · 1988
11990–1990
Abramowitz v. Posner green
ca2 · 1982
11989–1989
Casey v. Baseden green
ill · 1986
11986–1986
People v. Ogunsola green
ill · 1981
11984–1984
People v. Housby neutral
illappct · 1975
11984–1984
People v. Porter green
illappct · 1975
11977–1977
State Farm Mutual Automobile Insurance Co. v. Shelton green
kyctapphigh · 1963
11974–1974
Carolina Veneer & Lumber Co. v. American Mutual Liability Insurance neutral
· 1943
11974–1974
Jans v. City of Evanston green
illappct · 1964
11969–1969
Goodkind v. Bartlett green
ill · 1894
11926–1926
Bank of Montreal v. Griffin neutral
illappct · 1910
11915–1915
Schneider v. Turner green
ill · 1889
11915–1915

Statutes the citing opinions construe

IL § 735 ILCS 5/2-615 (5) IL § 735 ILCS 5/2-619 (4) IL § 725 ILCS 5/122-1 (3) IL § 725 ILCS 5/122-6 (3) USC § 46u.s.c.688 (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

TX 138 (1919–2026) CA 133 (1907–2026) FL 61 (1955–2026) IL 53 (1915–2025) NY 46 (1923–2024) PA 42 (1908–2024) WA 41 (1967–2026) LA 34 (1959–2024) MA 32 (1964–2026) OH 27 (1984–2026) CT 27 (1990–2025) IA 24 (1937–2026) MD 20 (1964–2019) WI 18 (1952–2025) MS 16 (1945–2019) CO 16 (1972–2026) MO 16 (1930–2019) IN 15 (1974–2017) GA 15 (1949–2026) NJ 14 (1914–2021) WY 13 (1977–2022) MI 13 (1916–2025) OK 13 (1933–2020) MN 12 (1893–2014) AL 10 (1926–2005) DC 10 (1976–2018) AZ 10 (1982–2024) OR 9 (1990–2026) KS 9 (1933–2021) VT 7 (1980–2013) MT 6 (1923–2016) ND 6 (2001–2022) ME 6 (2016–2023) NH 5 (1976–2017) ID 5 (2014–2022) NC 5 (1940–2012) DE 5 (1990–2026) TN 5 (1958–2016) VA 5 (1983–2006) UT 4 (1999–2015) WV 4 (1994–2026) SC 4 (1922–2020) NV 4 (1993–2016) NM 4 (2014–2018) KY 3 (2005–2025) SD 3 (1919–1999) AR 3 (1960–1987) NE 3 (1961–2021) AK 3 (1973–2024) VI 2 (2012–2014) HI 2 (1910–2018)

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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