two part standard (Illinois) · Go Syfert
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two part standard in Illinois

52 Illinois opinions name it 2 courts 1979–2026 22 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
Ornelas v. United Statesgreen
scotus · 1996 · cited in 8 Illinois opinions naming this issue, 2012–2021
2 sentences

2021People v. Woolley, 178 Ill. 2d 175, 198 (1997). ¶ 57 In reviewing a trial court’s ruling on a motion to suppress a statement, we apply the two- part standard of review announced in Ornelas v. United States, 517 U.S. 690, 699 (1996), and adopted by our supreme court in In re G.O., 191 Ill. 2d 37, 49-50 (2000).

2020July 1, 2018). ¶ 13 ANALYSIS ¶ 14 In reviewing a trial court’s ruling on a motion to suppress, we employ the two- part standard of review adopted by the United States Supreme Court in Ornelas v. United States, 517 U.S. 690 (1996).

78
People v. Luedemanngreen
ill · 2006 · cited in 7 Illinois opinions naming this issue, 2012–2021
2 sentences

2021People v. Luedemann, 222 Ill. 2d 530, 542 (2006); People v. Allard, 2018 IL App (2d) 160927, ¶ 22 .

2016We find that LaGrange’s encounter with defendants began as a consensual encounter, and only rose to the level of a seizure after LaGrange had formed the reasonable, articulable suspicion required to perform such a seizure under the fourth amendment. ¶ 26 “In reviewing a trial court’s ruling on a motion to suppress evidence, we apply the two- part standard of review ***.” People v. Luedemann, 222 Ill. 2d 530, 542 (2006).

37
People v. Harrisgreen
ill · 2008 · cited in 2 Illinois opinions naming this issue, 2022–2023
2 sentences

2023People v. Harris, 228 Ill. 2d 222, 230 (2008).

2022That is, while a “trial court’s findings of historical fact are reviewed for clear error,” a reviewing court “may assess the established facts in relation to the issues and may draw its own conclusion when deciding what relief, if any, should be granted.” People v. Harris, 228 Ill. 2d 222, 230 (2008). ¶ 51 Defendant does not dispute any of the trial court’s factual findings with respect to the motion to suppress.

22
Best v. Taylor MacHine Worksgreen
ill · 1997 · cited in 2 Illinois opinions naming this issue, 2020–2020
2 sentences

2020“Its purpose, as [the supreme court has] consistently held, is to prevent arbitrary legislative classifications that discriminate in favor of a select group without a sound, reasonable basis.” Moline School District No. 40, 2016 IL 119704, ¶ 18 (citing Best v. Taylor Machine Works, 179 Ill. 2d 367, 391 (1997)). ¶ 62 In assessing whether a statute violates the special legislation clause, courts apply a two- part analysis: “First, they must determine whether the statutory classification at issue discriminates in favor of a select group.

2020“Its purpose, as [the supreme court has] consistently held, is to prevent arbitrary legislative classifications that discriminate in favor of a select group without a sound, reasonable basis.” Moline School District No. 40, 2016 IL 119704, ¶ 18 (citing Best v. Taylor Machine Works, 179 Ill. 2d 367, 391 (1997)). ¶ 62 In assessing whether a statute violates the special legislation clause, courts apply a two- part analysis: “First, they must determine whether the statutory classification at issue discriminates in favor of a select group.

22
Big Sky Excavating, Inc. v. Illinois Bell Telephone Co.green
ill · 2005 · cited in 2 Illinois opinions naming this issue, 2020–2020
2 sentences

2020If it does, then they must go on to consider whether the classification is arbitrary.” Moline School District No. 40, 2016 IL 119704, ¶ 23 (citing Big Sky Excavating, Inc. v. Illinois Bell Telephone Co., 217 Ill. 2d 221, 235 (2005)).

2020If it does, then they must go on to consider whether the classification is arbitrary.” Moline School District No. 40, 2016 IL 119704, ¶ 23 (citing Big Sky Excavating, Inc. v. Illinois Bell Telephone Co., 217 Ill. 2d 221, 235 (2005)).

22
People v. Hopkinsgreen
ill · 2009 · cited in 2 Illinois opinions naming this issue, 2013–2020
2 sentences

2020People v. Hopkins, 235 Ill. 2d 453, 471 (2009).

2013People v. Hopkins, 235 Ill. 2d 453, 472 (2009). ¶ 12 In reviewing a ruling on a motion to quash arrest and suppress evidence, we apply a two- part standard of review.

22
Moline School District v. Quinngreen
ill · 2016 · cited in 2 Illinois opinions naming this issue, 2020–2020
2 sentences

2020“Its purpose, as [the supreme court has] consistently held, is to prevent arbitrary legislative classifications that discriminate in favor of a select group without a sound, reasonable basis.” Moline School District No. 40, 2016 IL 119704, ¶ 18 (citing Best v. Taylor Machine Works, 179 Ill. 2d 367, 391 (1997)). ¶ 62 In assessing whether a statute violates the special legislation clause, courts apply a two- part analysis: “First, they must determine whether the statutory classification at issue discriminates in favor of a select group.

2020“Its purpose, as [the supreme court has] consistently held, is to prevent arbitrary legislative classifications that discriminate in favor of a select group without a sound, reasonable basis.” Moline School District No. 40, 2016 IL 119704, ¶ 18 (citing Best v. Taylor Machine Works, 179 Ill. 2d 367, 391 (1997)). ¶ 62 In assessing whether a statute violates the special legislation clause, courts apply a two- part analysis: “First, they must determine whether the statutory classification at issue discriminates in favor of a select group.

22
People v. Johnsongreen
ill · 2010 · cited in 2 Illinois opinions naming this issue, 2011–2017
2 sentences

2017Further, “[r]easonableness under -6- No. 1-14-3255 the fourth amendment generally requires a warrant supported by probable cause.” People v. Johnson, 237 Ill. 2d 81, 89 (2010). ¶ 18 When reviewing a trial court’s ruling on a motion to suppress evidence, we apply a two- part standard of review adopted by the Supreme Court in Ornelas v. United States, 517 U.S. 690, 699 (1996).

2017Johnson, 237 Ill. 2d at 88 .

22
People v. Weargreen
ill · 2008 · cited in 2 Illinois opinions naming this issue, 2013–2016
2 sentences

2016City of Highland Park v. Kane, 2013 IL App (2d) 120788, ¶ 11 (citing People v. Wear, 229 Ill. 2d 545, 560-61 (2008)).

2013See id. at 560-61 .

22
State v. Martinezgreen
nmctapp · 2002 · cited in 2 Illinois opinions naming this issue, 2004–2004
2 sentences

2004A party attempts to prolong the voir dire when he asks irrelevant, immaterial, or repetitious questions"); see also Martinez , 131 N.M. at 755 , 42 P.3d at 860 (noting that with better organization of her voir dire , counsel could have asked the questions claimed to be precluded within the trial court's time limits).

2004A party attempts to prolong the voir dire when he asks irrelevant, immaterial, or repetitious questions"); see also Martinez , 131 N.M. at 755 , 42 P.3d at 860 (noting that with better organization of her voir dire , counsel could have asked the questions claimed to be precluded within the trial court's time limits).

22
Professional Real Estate Investors, Inc. v. Columbia Pictures Industries, Inc.green
scotus · 1993 · cited in 1 Illinois opinions naming this issue, 2024–2024
1 sentence

2024Id. at 861 (citing Professional Real Estate Investors, Inc. v. Columbia Pictures Industries, Inc., 508 U.S. 49, 52, 60-61 (1993)). ¶ 66 Based on the legislative history and language of the Act, which mirrored the “sham exception,” the appellate court in Sandholm concluded that, in analyzing whether a defendant’s acts are in furtherance of government participation within the meaning of the Act, an adaptation of the two-part test for the “sham exception” is appropriate.

11
In Re GOgreen
ill · 2000 · cited in 1 Illinois opinions naming this issue, 2021–2021
11
People v. Woolleygreen
ill · 1997 · cited in 1 Illinois opinions naming this issue, 2021–2021
11
People v. Petrenkogreen
ill · 2010 · cited in 1 Illinois opinions naming this issue, 2021–2021
11
People v. Pitmangreen
ill · 2004 · cited in 1 Illinois opinions naming this issue, 2020–2020
11
City of Highland Park v. Kanegreen
illappct · 2013 · cited in 1 Illinois opinions naming this issue, 2016–2016
11
United States v. Lovascogreen
scotus · 1977 · cited in 1 Illinois opinions naming this issue, 2013–2013
11
People v. Olivergreen
ill · 2010 · cited in 1 Illinois opinions naming this issue, 2011–2011
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 (32)

CaseCitedYears
People v. Grant green
ill · 2013
2 sentences

2024People v. Grant, 2013 IL 112734, ¶ 12 .

2022He suggests that the State’s case would have been much weaker without this evidence, and thus he asks that we reverse and remand for a new trial. ¶ 50 “In reviewing a ruling on a motion to quash arrest and suppress evidence, we apply a two- part standard of review. [Citation.] While we accord great deference to the trial court’s factual findings, and will reverse those findings only if they are against the manifest weight of the evidence, we review de novo the court’s ultimate ruling on a motion to suppress involving probable cause. [Citation.]” People v. Grant, 2013 IL 112734, ¶ 12 .

32022–2024
Strickland v. Washington green
scotus · 1984
2 sentences

2021The familiar two- part test of Strickland v. Washington, 466 U.S. 668 (1984), is used to evaluate claims of ineffective assistance of counsel, and it applies to both trial counsel and appellate counsel.

2017In defendant’s view, had a third party witnessed the conversation, that person could have impeached Coleman’s testimony by testifying consistently with Keenan’s version of the February 6, 2014 conversation. ¶ 40 When evaluating an ineffective assistance of counsel claim, this court applies the two- part test set forth in Strickland v. Washington, 466 U.S. 668 (1984).

32010–2021
New York State Rifle & Pistol Assn., Inc. v. Bruen green
scotus · 2022
2 sentences

2025Bruen, 597 U.S. at 24 .

2025Bruen, 597 U.S. at 24 .

22025–2025
People v. Brooks green
ill · 2017
2 sentences

2024Id. ¶ 50 When reviewing the trial court’s ruling on a motion to suppress evidence, we apply a two- part standard of review.

2022Id. ¶ 42 In reviewing the circuit court’s ruling on a motion to suppress evidence, we apply a two- part standard of review.

22022–2024
People v. Hagestedt green
ill · 2025
1 sentence

2026People v. Hagestedt, 2025 IL 130286, ¶ 14 .

12026–2026
People v. Villareal green
ill · 2023
1 sentence

2026Specifically, defendant asserts that (1) Second Amendment protections apply to all Americans, We will refer to this offense by its prior name to conform with the version of the statute under which defendant was charged. -2- No. 1-25-0250 including those with felony convictions in their criminal histories, and (2) no historical analogue exists for a ban on the right to carry a firearm based on previous convictions. ¶6 A party bringing a facial constitutional challenge to a statute faces a “particularly heavy burden,” as the party “must prove there is no set of circumstances under which the stat

12026–2026
City of Columbia v. Omni Outdoor Advertising, Inc. green
scotus · 1991
1 sentence

2024Id. at 861 (citing Professional Real Estate Investors, Inc. v. Columbia Pictures Industries, Inc., 508 U.S. 49, 52, 60-61 (1993)). ¶ 66 Based on the legislative history and language of the Act, which mirrored the “sham exception,” the appellate court in Sandholm concluded that, in analyzing whether a defendant’s acts are in furtherance of government participation within the meaning of the Act, an adaptation of the two-part test for the “sham exception” is appropriate.

12024–2024
Wilson v. County of Cook green
ill · 2012
1 sentence

2024In Illinois, our supreme court in Wilson v. County of Cook, 2012 IL 112026, ¶ 41 , adopted this two- part test for analyzing challenges to the second amendment.

12024–2024
People ex rel. Alvarez v. Howard green
ill · 2016
1 sentence

2024Alvarez v. Howard, 2016 IL 120729, ¶¶ 19-20 , established a two part test for retroactivity: (1) if the statute “clearly” indicates its “temporal reach,” the legislature’s expressed intent will be applied; (2) if no temporal reach is expressed, then the court must examine the “retroactive impact” of the law or rule.

12024–2024
People v. Torres green
ill · 2024
1 sentence

2024People v. Torres, 2024 IL 129289, ¶¶ 26-27 .

12024–2024
People v. Mosley green
ill · 2015
1 sentence

2024Mosley, 2015 IL 115872, ¶ 34 ; see In re D.B., 2023 IL App (1st) 231146-U, ¶ 24 , pet. for leave to appeal pending, No. 130425 (filed 6 No. 1-23-0568 Feb. 2, 2024); Interest of C.P., 2023 IL App (1st) 231033-U, ¶ 5 .

12024–2024
People v.Salamon green
ill · 2022
1 sentence

2023People v. Salamon, 2022 IL 125722, ¶ 75 .

12023–2023
People v. Workheiser green
illappct · 2022
1 sentence

2023“This court employs a two- part standard in reviewing a circuit court’s denial of a motion to suppress.” People v. Workheiser, 2022 IL App (3d) 200450, ¶ 22 .

12023–2023
People v. Holmes green
ill · 2017
1 sentence

2022People v. Holmes, 2017 IL 120407, ¶ 9 .

12022–2022
People v. Carter green
ill · 2021
1 sentence

2022People v. Carter, 2021 IL 125954, ¶ 21 .

12022–2022
People v. Ramsey green
illappct · 2017
1 sentence

2022People v. Kulpin, 2021 IL App (2d) 180696, ¶ 41 ; 2021 IL App (1st) 190692 , ¶ 48; People v. Ramsey, 2017 IL App (1st) 160977, ¶ 24 .

12022–2022
People v. Aljohani green
illappct · 2021
12022–2022
People v. Kulpin green
illappct · 2021
12022–2022
People v. Bass green
ill · 2021
1 sentence

2022Here, we find that defendant has not established prejudice. ¶ 16 Defendant relies on Bass, 2019 IL App (1st) 160640 , aff’d in part and vacated in part, 2021 IL 125434 , to argue his arrest pursuant to a “stop order” alert rather than an arrest warrant was unconstitutional, and the trial court therefore erred by denying his motion to quash arrest and suppress statement. -5- No. 1-20-0660 ¶ 17 In reviewing a ruling on a motion to quash arrest and suppress evidence, we apply a two- part standard of review.

12022–2022
People v. Bass green
illappct · 2019
1 sentence

2022Here, we find that defendant has not established prejudice. ¶ 16 Defendant relies on Bass, 2019 IL App (1st) 160640 , aff’d in part and vacated in part, 2021 IL 125434 , to argue his arrest pursuant to a “stop order” alert rather than an arrest warrant was unconstitutional, and the trial court therefore erred by denying his motion to quash arrest and suppress statement. -5- No. 1-20-0660 ¶ 17 In reviewing a ruling on a motion to quash arrest and suppress evidence, we apply a two- part standard of review.

12022–2022
People v. Almond green
ill · 2015
1 sentence

2022People v. Almond, 2015 IL 113817 , ¶ 55.

12022–2022
People v. Allard green
illappct · 2018
12021–2021
People v. Braggs green
ill · 2004
12021–2021
People v. Timmsen green
ill · 2016
12020–2020
People v. Henderson green
ill · 2013
12020–2020
People v. Eubanks green
ill · 2019
12020–2020
People v. Evans green
ill · 1999
12017–2017
People v. Sanders green
illappct · 2013
12014–2014
Neil v. Biggers green
scotus · 1972
12002–2002
Wakefield v. Kern green
illappct · 1978
12000–2000
Pekelder v. Edgewater Automotive Co. green
ill · 1977
11997–1997
Manson v. Brathwaite green
scotus · 1977
11979–1979

Statutes the citing opinions construe

IL § 720 ILCS 5/24-1.1 (4) IL § 720 ILCS 5/24-1.6 (4) IL § 720 ILCS 5/24-1.7 (3) IL § 720 ILCS 570/402 (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

CT 323 (1980–2026) LA 169 (1982–2024) TX 121 (1973–2024) OH 80 (1998–2026) IN 66 (1983–2024) IL 52 (1979–2026) PA 51 (1981–2025) WA 45 (1999–2025) MS 41 (1987–2024) TN 31 (1997–2018) CA 28 (1976–2026) DE 27 (1979–2025) NC 24 (1987–2026) NJ 23 (1991–2026) OK 16 (1985–2023) MD 15 (1979–2023) WI 15 (1989–2025) OR 14 (1979–2021) MI 12 (1994–2023) MO 12 (1981–2010) SD 11 (1991–2017) CO 11 (1985–2026) GA 11 (1990–2024) VA 11 (1987–2023) UT 10 (1988–2024) IA 9 (1986–2023) FL 8 (1989–2013) AZ 7 (1984–2026) WV 7 (1992–2020) NM 7 (1969–2025) MT 7 (1984–2010) VT 6 (1987–2019) NY 5 (2004–2016) MA 5 (1999–2025) HI 5 (1993–2023) SC 4 (1988–2005) KY 4 (2002–2020) KS 4 (2020–2025) ID 4 (1988–2019) RI 4 (1974–1999) NV 3 (1988–2017) NE 3 (2000–2023) DC 3 (1980–2005) ME 3 (2000–2021) ND 3 (2004–2007) MN 2 (1986–1987) AR 2 (1985–2015)

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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