beyond-a-reasonable-doubt standard (Illinois) · Go Syfert
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beyond-a-reasonable-doubt standard in Illinois

50 Illinois opinions name it 2 courts 1979–2026 24 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 (29)

CaseFollowedCited
People v. Craiggreen
illappct · 2010 · cited in 16 Illinois opinions naming this issue, 2018–2025
2 sentences

2025“Although this description is stated in terms of reasonable doubt, our courts consider clear and convincing evidence to be more than a preponderance of the evidence and not quite approaching the beyond-a-reasonable-doubt standard necessary to convict a person of a criminal offense.” People v. Craig, 403 Ill.

2025“Although this description is stated in terms of reasonable doubt, our courts consider clear and convincing evidence to be more than a preponderance of the evidence and not quite approaching the beyond-a-reasonable-doubt standard necessary to convict a person of a criminal offense.” People v. Craig, 403 Ill.

1616
In Re DTgreen
ill · 2004 · cited in 4 Illinois opinions naming this issue, 2010–2018
2 sentences

2018App. 3d 762, 768 (2010) (citing In re D.T., 212 Ill. 2d 347, 362 (2004) and Bazydlo v. Volant, 164 Ill. 2d 207, 213 (1995)). ¶ 57 Additionally, a “truly persuasive demonstration of innocence” by “compelling evidence,” (Washington, 171 Ill. 2d at 488-89 ) may be made by presenting evidence of the type articulated in Schlup, 513 U.S. at 324 (“exculpatory scientific evidence, trustworthy eyewitness accounts, or critical physical evidence”) or other evidence of a similarly significant character. ¶ 58 Requiring a defendant to present a “truly persuasive demonstration of innocence” in the form of “c

2018App. 3d 762, 768 (2010) (citing In re D.T., 212 Ill. 2d 347, 362 (2004) and Bazydlo v. Volant, 164 Ill. 2d 207, 213 (1995)). ¶ 57 Additionally, a “truly persuasive demonstration of innocence” by “compelling evidence,” (Washington, 171 Ill. 2d at 488-89 ) may be made by presenting evidence of the type articulated in Schlup, 513 U.S. at 324 (“exculpatory scientific evidence, trustworthy eyewitness accounts, or critical physical evidence”) or other evidence of a similarly significant character. ¶ 58 Requiring a defendant to present a “truly persuasive demonstration of innocence” in the form of “c

44
Holland v. United Statesgreen
scotus · 1955 · cited in 4 Illinois opinions naming this issue, 2012–2014
2 sentences

2014The Court began by laying out the analytical framework for such claims: “The beyond a reasonable doubt standard is a requirement of due process, but the Constitution neither prohibits trial courts from defining reasonable doubt nor requires them to do so as a matter of course. [Citation.] Indeed, so long as the court instructs the jury on the necessity that the defendant’s guilt be proved beyond a reasonable doubt, [citation], the Constitution does not require that any particular form of words be used in advising the jury of the government’s burden of proof. [Citation.] Rather, ‘taken as a who

2014The Court began by laying out the analytical framework for such claims: “The beyond a reasonable doubt standard is a requirement of due process, but the Constitution neither prohibits trial courts from defining reasonable doubt nor requires them to do so as a matter of course. [Citation.] Indeed, so long as the court instructs the jury on the necessity that the defendant’s guilt be proved beyond a reasonable doubt, -7- 2014 IL App (2d) 121203 [citation], the Constitution does not require that any particular form of words be used in advising the jury of the government’s burden of proof. [Citati

44
In Re Marriage of Wechselbergergreen
illappct · 1983 · cited in 2 Illinois opinions naming this issue, 2021–2026
2 sentences

2026In re Marriage of Wechselberger, 115 Ill.

2021In re Marriage of Wechselberger, 115 Ill.

22
In Re EHgreen
ill · 2006 · cited in 2 Illinois opinions naming this issue, 2015–2021
2 sentences

2021See, e.g., In re E.H., 224 Ill. 2d 172, 180-81 (2006) (explaining that the harmless-error-review standard for evidentiary issues is the reasonable-probability standard, whereas the harmless-error-review standard for constitutional issues is the beyond-a-reasonable-doubt standard); People v. McBride, 2020 IL App (2d) 170873, ¶¶ 34-38 (same); see also People v. Pelo, 404 Ill.

2015People v. Stull, 2014 IL App (4th) 120704, ¶ 104 , 5 N.E.3d 328 ; In re E.H., 224 Ill. 2d 172, 180 , 863 N.E.2d 231, 235 (2006).

22
Schlup v. Delored
scotus · 1995 · cited in 2 Illinois opinions naming this issue, 2018–2018
2 sentences

2018App. 3d 762, 768 (2010) (citing In re D.T., 212 Ill. 2d 347, 362 (2004) and Bazydlo v. Volant, 164 Ill. 2d 207, 213 (1995)). ¶ 57 Additionally, a “truly persuasive demonstration of innocence” by “compelling evidence,” (Washington, 171 Ill. 2d at 488-89 ) may be made by presenting evidence of the type articulated in Schlup, 513 U.S. at 324 (“exculpatory scientific evidence, trustworthy eyewitness accounts, or critical physical evidence”) or other evidence of a similarly significant character. ¶ 58 Requiring a defendant to present a “truly persuasive demonstration of innocence” in the form of “c

2018App. 3d 762, 768 (2010) (citing In re D.T., 212 Ill. 2d 347, 362 (2004) and Bazydlo v. Volant, 164 Ill. 2d 207, 213 (1995)). ¶ 57 Additionally, a “truly persuasive demonstration of innocence” by “compelling evidence,” (Washington, 171 Ill. 2d at 488-89 ) may be made by presenting evidence of the type articulated in Schlup, 513 U.S. at 324 (“exculpatory scientific evidence, trustworthy eyewitness accounts, or critical physical evidence”) or other evidence of a similarly significant character. ¶ 58 Requiring a defendant to present a “truly persuasive demonstration of innocence” in the form of “c

22
The United States of America v. Barney Glassgreen
ca7 · 1988 · cited in 2 Illinois opinions naming this issue, 2014–2014
2 sentences

2014See United States v. Glass, 846 F.2d 386, 387 (7th Cir. 1988) (“ ‘Reasonable doubt’ must speak for itself.

2014See United States v. Glass, 846 F.2d 386, 387 (7th Cir. 1988) (“ ‘Reasonable doubt’ must speak for itself.

22
The People v. Malmenatogreen
ill · 1958 · cited in 2 Illinois opinions naming this issue, 2012–2012
2 sentences

2012See, e.g., Malmenato, 14 Ill. 2d at 61 ; Speight, 153 Ill. 2d at 374-75 . ¶ 54 However, when considering the due process implications of an instruction that defined reasonable doubt to the jury, the United States Supreme Court stated in Victor v. Nebraska, 511 U.S. 1 (1994): “The beyond a reasonable doubt standard is a requirement of due process, but the Constitution neither prohibits trial courts from defining reasonable doubt nor requires them to do so as a matter of course. [Citation.] Indeed, so long as the court instructs the jury on the necessity that the defendant’s guilt be proved beyo

2012See, e.g., Malmenato, 14 Ill. 2d at 61 ; Speight, 153 Ill. 2d at 374-75 . ¶ 48 However, when considering the due process implications of an instruction that defined reasonable doubt to the jury, the United States Supreme Court stated in Victor v. Nebraska: “The beyond a reasonable doubt standard is a requirement of due process, but the Constitution neither prohibits trial courts from defining reasonable doubt nor requires them to do so as a matter of course. [Citation.] Indeed, so long as the court instructs the jury on the necessity that the defendant’s guilt be proved beyond a reasonable dou

22
In Re Detention of Kishgreen
illappct · 2009 · cited in 2 Illinois opinions naming this issue, 2010–2010
2 sentences

2010App. 3d at 555-56 , 916 N.E.2d at 602 (there is no logical contradiction in the Act's use of the beyond-a-reasonable-doubt standard in the initial commitment proceeding and the preponderance-of-the-evidence standard in a conditional-release-revocation proceeding).

2010App. 3d at 555-56 , 916 N.E.2d at 602 (there is no logical contradiction in the Act’s use of the beyond-a-reasonable-doubt standard in the initial commitment proceeding and the preponderance-of-the-evidence standard in a conditional-release-revocation proceeding).

22
In Re Neil C.green
md · 1987 · cited in 2 Illinois opinions naming this issue, 2000–2000
2 sentences

2000App. 3d at 671 ; accord Fitzgerald v. Superior Court, 173 Ariz. 539, 548 , 845 P.2d 465, 474 (App. 1992); In re Neil C., 308 Md. 591, 594-95 , 521 A.2d 329, 331 (1987).

2000App. 3d at 671 ; accord Fitzgerald v. Superior Court, 173 Ariz. 539, 548 , 845 P.2d 465, 474 (App. 1992); In re Neil C., 308 Md. 591, 594-95 , 521 A.2d 329, 331 (1987).

22
Fitzgerald v. Superior Courtgreen
arizctapp · 1992 · cited in 2 Illinois opinions naming this issue, 2000–2000
2 sentences

2000App. 3d at 671 ; accord Fitzgerald v. Superior Court, 173 Ariz. 539, 548 , 845 P.2d 465, 474 (App. 1992); In re Neil C., 308 Md. 591, 594-95 , 521 A.2d 329, 331 (1987).

2000App. 3d at 671 ; accord Fitzgerald v. Superior Court, 173 Ariz. 539, 548 , 845 P.2d 465, 474 (App. 1992); In re Neil C., 308 Md. 591, 594-95 , 521 A.2d 329, 331 (1987).

22
People v. Moralesgreen
illappct · 2024 · cited in 4 Illinois opinions naming this issue, 2025–2026
2 sentences

2026Clear and convincing evidence is “that quantum of proof that leaves no reasonable doubt in the mind of the fact finder about the truth of the proposition in question” (internal quotation marks omitted) (People v. White, 2024 IL App (1st) 232245, ¶ 19 ), although it is a less demanding standard than the beyond-a-reasonable-doubt standard necessary for a conviction (People v. Morales, 2024 IL App (2d) 230597, ¶ 15 ).

2026Id. §§ 110-6.1(e)(1)-(3), 110-10(b). ¶ 22 “Clear and convincing evidence” has been described as “that quantum of proof that leaves no reasonable doubt in the mind of the fact finder about the truth of the proposition in question” (internal quotation marks omitted) (People v. White, 2024 IL App (1st) 232245, ¶ 19 ), although it is a less demanding standard than the beyond-a-reasonable-doubt standard necessary for a conviction (People v. Morales, 2024 IL App (2d) 230597, ¶ 15 ).

14
Victor v. Nebraskagreen
scotus · 1994 · cited in 4 Illinois opinions naming this issue, 1995–2014
2 sentences

2014The Court began by laying out the analytical framework for such claims: “The beyond a reasonable doubt standard is a requirement of due process, but the Constitution neither prohibits trial courts from defining reasonable doubt nor requires them to do so as a matter of course. [Citation.] Indeed, so long as the court instructs the jury on the necessity that the defendant’s guilt be proved beyond a reasonable doubt, [citation], the Constitution does not require that any particular form of words be used in advising the jury of the government’s burden of proof. [Citation.] Rather, ‘taken as a who

2012See, e.g., Malmenato, 14 Ill. 2d at 61 ; Speight, 153 Ill. 2d at 374-75 . ¶ 54 However, when considering the due process implications of an instruction that defined reasonable doubt to the jury, the United States Supreme Court stated in Victor v. Nebraska, 511 U.S. 1 (1994): “The beyond a reasonable doubt standard is a requirement of due process, but the Constitution neither prohibits trial courts from defining reasonable doubt nor requires them to do so as a matter of course. [Citation.] Indeed, so long as the court instructs the jury on the necessity that the defendant’s guilt be proved beyo

14
People v. Evansgreen
illappct · 2016 · cited in 2 Illinois opinions naming this issue, 2018–2019
2 sentences

2019He then reiterated that the jurors could have questions, “as long as those questions don’t amount to a reasonable doubt.” This argument was an improper attempt to define and dilute the State’s burden of proof (see People v. Evans, 2016 IL App (3d) 140120, ¶ 59 (prosecutor’s rebuttal remarks improperly conflated the beyond-a-reasonable- doubt standard with a question of whether the defendant’s actions were reasonable, lessening the State’s burden of proof)), and nothing close to it is permitted on retrial.

2018He then reiterated that the jurors could have questions, "as long as those questions don't amount to a reasonable doubt." This argument was an improper attempt to define and dilute the State's burden of proof (see People v. Evans , 2016 IL App (3d) 140120 , ¶ 59, 406 Ill.Dec. 175 , 60 N.E.3d 77 (prosecutor's rebuttal remarks improperly conflated the beyond-a-reasonable-doubt standard with a question of whether the defendant's actions were reasonable, lessening the State's burden of proof) ), and nothing close to it is permitted on retrial.

12
People v. Minniweathergreen
illappct · 1998 · cited in 2 Illinois opinions naming this issue, 2011–2011
2 sentences

2011Jackson v. Virginia, 443 U.S. 307, 319 , 99 S.Ct. 2781 , 61 L.Ed.2d 560 (1979); People v. Minniweather, 301 Ill.App.3d 574, 577 , 234 Ill.Dec. 812 , 703 N.E.2d 912 (1998).

2011Jackson v. Virginia, 443 U.S. 307, 319 , 99 S.Ct. 2781 , 61 L.Ed.2d 560 (1979); People v. Minniweather, 301 Ill.App.3d 574, 577 , 234 Ill.Dec. 812 , 703 N.E.2d 912 (1998).

12
Jackson v. Virginiared
scotus · 1979 · cited in 2 Illinois opinions naming this issue, 2011–2011
2 sentences

2011Jackson v. Virginia, 443 U.S. 307, 319 , 99 S.Ct. 2781 , 61 L.Ed.2d 560 (1979); People v. Minniweather, 301 Ill.App.3d 574, 577 , 234 Ill.Dec. 812 , 703 N.E.2d 912 (1998).

2011Jackson v. Virginia, 443 U.S. 307, 319 , 99 S.Ct. 2781 , 61 L.Ed.2d 560 (1979); People v. Minniweather, 301 Ill.App.3d 574, 577 , 234 Ill.Dec. 812 , 703 N.E.2d 912 (1998).

12
People v. Jacksongreen
ill · 1992 · cited in 1 Illinois opinions naming this issue, 2026–2026
1 sentence

2026People v. Holman, 2025 IL App (2d) 240513, ¶ 56 ; see People v. Jackson, 149 Ill. 2d 540, 549 (1992) (“We need not decide now if - 17 - any specific traditional standard of proof applies at sentencing.

11
People v. Wrightgreen
illappct · 2016 · cited in 1 Illinois opinions naming this issue, 2025–2025
1 sentence

2025See, e.g., People v. Wright, 2016 IL App (5th) 120310, ¶ 33 ; Fort, 2014 IL App (1st) 120037, ¶ 19 ; Newton, 369 F.3d at 679 . ¶ 44 In harmless error review, courts may “(1) focus on the error to determine whether it might have contributed to the conviction, (2) examine the other evidence in the case to see if overwhelming evidence supports the conviction, and (3) determine whether the improperly admitted evidence is merely cumulative or duplicates properly admitted evidence.” People v. Salamon, 2022 IL 125722, ¶ 121 . ¶ 45 To convict Rainey of the AHC charge, the State had to prove he (1) eit

11
People of Illinois v. Rhodesgreen
ill · 1981 · cited in 1 Illinois opinions naming this issue, 2024–2024
11
People v. Campbellgreen
ill · 1992 · cited in 1 Illinois opinions naming this issue, 2024–2024
11
People v. McDonaldgreen
ill · 1995 · cited in 1 Illinois opinions naming this issue, 2024–2024
11
People v. Clinegreen
ill · 2022 · cited in 1 Illinois opinions naming this issue, 2024–2024
11
People v. Galangreen
ill · 2008 · cited in 1 Illinois opinions naming this issue, 2023–2023
11
Gerstein v. Pughgreen
scotus · 1975 · cited in 1 Illinois opinions naming this issue, 2023–2023
11
People v. McBridegreen
illappct · 2020 · cited in 1 Illinois opinions naming this issue, 2021–2021
11
People v. Veachgreen
ill · 2017 · cited in 1 Illinois opinions naming this issue, 2021–2021
11
People v. Pelogreen
illappct · 2010 · cited in 1 Illinois opinions naming this issue, 2021–2021
11
People v. Greengreen
ill · 2007 · cited in 1 Illinois opinions naming this issue, 2012–2012
11
People v. Smithgreen
illappct · 1981 · cited in 1 Illinois opinions naming this issue, 1986–1986
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 (24)

CaseCitedYears
Bazydlo v. Volant green
ill · 1995
2 sentences

2018App. 3d 762, 768 (2010) (citing In re D.T., 212 Ill. 2d 347, 362 (2004) and Bazydlo v. Volant, 164 Ill. 2d 207, 213 (1995)). ¶ 57 Additionally, a “truly persuasive demonstration of innocence” by “compelling evidence,” (Washington, 171 Ill. 2d at 488-89 ) may be made by presenting evidence of the type articulated in Schlup, 513 U.S. at 324 (“exculpatory scientific evidence, trustworthy eyewitness accounts, or critical physical evidence”) or other evidence of a similarly significant character. ¶ 58 Requiring a defendant to present a “truly persuasive demonstration of innocence” in the form of “c

2018App. 3d 762, 768 (2010) (citing In re D.T., 212 Ill. 2d 347, 362 (2004) and Bazydlo v. Volant, 164 Ill. 2d 207, 213 (1995)). ¶ 57 Additionally, a “truly persuasive demonstration of innocence” by “compelling evidence,” (Washington, 171 Ill. 2d at 488-89 ) may be made by presenting evidence of the type articulated in Schlup, 513 U.S. at 324 (“exculpatory scientific evidence, trustworthy eyewitness accounts, or critical physical evidence”) or other evidence of a similarly significant character. ¶ 58 Requiring a defendant to present a “truly persuasive demonstration of innocence” in the form of “c

42010–2018
People v. Speight green
ill · 1992
2 sentences

2012See, e.g., Malmenato, 14 Ill. 2d at 61 ; Speight, 153 Ill. 2d at 374-75 . ¶ 54 However, when considering the due process implications of an instruction that defined reasonable doubt to the jury, the United States Supreme Court stated in Victor v. Nebraska, 511 U.S. 1 (1994): “The beyond a reasonable doubt standard is a requirement of due process, but the Constitution neither prohibits trial courts from defining reasonable doubt nor requires them to do so as a matter of course. [Citation.] Indeed, so long as the court instructs the jury on the necessity that the defendant’s guilt be proved beyo

2012See, e.g., Malmenato, 14 Ill. 2d at 61 ; Speight, 153 Ill. 2d at 374-75 . ¶ 48 However, when considering the due process implications of an instruction that defined reasonable doubt to the jury, the United States Supreme Court stated in Victor v. Nebraska: “The beyond a reasonable doubt standard is a requirement of due process, but the Constitution neither prohibits trial courts from defining reasonable doubt nor requires them to do so as a matter of course. [Citation.] Indeed, so long as the court instructs the jury on the necessity that the defendant’s guilt be proved beyond a reasonable dou

31995–2012
People v. White green
illappct · 2024
2 sentences

2026Clear and convincing evidence is “that quantum of proof that leaves no reasonable doubt in the mind of the fact finder about the truth of the proposition in question” (internal quotation marks omitted) (People v. White, 2024 IL App (1st) 232245, ¶ 19 ), although it is a less demanding standard than the beyond-a-reasonable-doubt standard necessary for a conviction (People v. Morales, 2024 IL App (2d) 230597, ¶ 15 ).

2026Id. §§ 110-6.1(e)(1)-(3), 110-10(b). ¶ 22 “Clear and convincing evidence” has been described as “that quantum of proof that leaves no reasonable doubt in the mind of the fact finder about the truth of the proposition in question” (internal quotation marks omitted) (People v. White, 2024 IL App (1st) 232245, ¶ 19 ), although it is a less demanding standard than the beyond-a-reasonable-doubt standard necessary for a conviction (People v. Morales, 2024 IL App (2d) 230597, ¶ 15 ).

22026–2026
People v. Washington green
ill · 1996
2 sentences

2018App. 3d 762, 768 (2010) (citing In re D.T., 212 Ill. 2d 347, 362 (2004) and Bazydlo v. Volant, 164 Ill. 2d 207, 213 (1995)). ¶ 57 Additionally, a “truly persuasive demonstration of innocence” by “compelling evidence,” (Washington, 171 Ill. 2d at 488-89 ) may be made by presenting evidence of the type articulated in Schlup, 513 U.S. at 324 (“exculpatory scientific evidence, trustworthy eyewitness accounts, or critical physical evidence”) or other evidence of a similarly significant character. ¶ 58 Requiring a defendant to present a “truly persuasive demonstration of innocence” in the form of “c

2018App. 3d 762, 768 (2010) (citing In re D.T., 212 Ill. 2d 347, 362 (2004) and Bazydlo v. Volant, 164 Ill. 2d 207, 213 (1995)). ¶ 57 Additionally, a “truly persuasive demonstration of innocence” by “compelling evidence,” (Washington, 171 Ill. 2d at 488-89 ) may be made by presenting evidence of the type articulated in Schlup, 513 U.S. at 324 (“exculpatory scientific evidence, trustworthy eyewitness accounts, or critical physical evidence”) or other evidence of a similarly significant character. ¶ 58 Requiring a defendant to present a “truly persuasive demonstration of innocence” in the form of “c

22018–2018
People v. Turman green
illappct · 2011
2 sentences

2014Turman and Franklin ¶ 30 In 2011, the First District Appellate Court issued Turman, 2011 IL App (1st) 091019, ¶ 19 , in which it held that the trial court committed reversible error when it answered a jury’s request for a definition of “reasonable doubt” by saying that “ ‘reasonable doubt is not defined under Illinois law.

2014Turman and Franklin ¶ 30 In 2011, the First District Appellate Court issued Turman, 2011 IL App (1st) 091019, ¶ 19 , in which it held that the trial court committed reversible error when it answered a jury’s request for a definition of “reasonable doubt” by saying that “ ‘reasonable doubt is not defined under Illinois law.

22014–2014
People v. Sams green
illappct · 2014
2 sentences

2014App. 3d 120, 130 (2007). ¶ 80 Here, as in People v. Sams, 2013 IL App (1st) 121431, ¶ 16 , since “the State presented no physical evidence connecting [respondent] to the [bike],” and no evidence that the respondent knowingly intended to permanently deprive the owner of her specific bicycle, we should find - 17 - that the State has not met its burden of proving beyond a reasonable doubt that respondent is guilty. ¶ 81 Finally, the respondent raises the issue of due process, i.e., that the hearsay statements went unchallenged by cross-examination, which is a constitutional question and would hav

2014App. 3d 120, 130 (2007). ¶ 80 Here, as in People v. Sams, 2013 IL App (1st) 121431, ¶ 16 , since "the State presented no physical evidence connecting [respondent] to the [bike]", and no evidence that the respondent knowingly intended to permanently deprive the owner of her specific bicycle, we should find that the State has not met its burden of proving beyond a reasonable doubt that respondent is guilty. ¶ 81 Finally, the respondent raises the issue of due process, i.e., that the hearsay statements 31 No. 1-10-3835 went unchallenged by cross–examination which is a constitutional question and

22014–2014
People v. Trainor green
ill · 2001
2 sentences

2010Trainor, 196 Ill. 2d at 335 , 752 N.E.2d at 1065 .

2010Trainor, 196 Ill. 2d at 335 , 752 N.E.2d at 1065 .

22010–2010
People v. Buonavolanto green
illappct · 1992
2 sentences

2000“Because this issue had been decided unfavorably to the State under a preponderance of the evidence standard of proof, the State is barred from proceeding against defendant under a beyond a reasonable doubt standard.” Buonavolanto, 238 Ill.

2000"Because this issue had been decided unfavorably to the State under a preponderance of the evidence standard of proof, the State is barred from proceeding against defendant under a beyond a reasonable doubt standard." Buonavolanto , 238 Ill.

22000–2000
People v. Holman green
illappct · 2025
1 sentence

2026People v. Holman, 2025 IL App (2d) 240513, ¶ 56 ; see People v. Jackson, 149 Ill. 2d 540, 549 (1992) (“We need not decide now if - 17 - any specific traditional standard of proof applies at sentencing.

12026–2026
People v.Salamon green
ill · 2022
1 sentence

2025See, e.g., People v. Wright, 2016 IL App (5th) 120310, ¶ 33 ; Fort, 2014 IL App (1st) 120037, ¶ 19 ; Newton, 369 F.3d at 679 . ¶ 44 In harmless error review, courts may “(1) focus on the error to determine whether it might have contributed to the conviction, (2) examine the other evidence in the case to see if overwhelming evidence supports the conviction, and (3) determine whether the improperly admitted evidence is merely cumulative or duplicates properly admitted evidence.” People v. Salamon, 2022 IL 125722, ¶ 121 . ¶ 45 To convict Rainey of the AHC charge, the State had to prove he (1) eit

12025–2025
People v. Reed green
illappct · 2023
1 sentence

2025People v. Reed, 2023 IL App (1st) 231834, ¶ 25 ; see Morales, 2024 IL App (2d) 230597, ¶ 15 (stating that the clear-and-convincing standard is less than the beyond-a-reasonable- doubt standard). ¶ 39 In short, the circuit court here did not err in finding that the State established by clear and convincing evidence that the proof was evident or the presumption great that Mr. Hughes committed the qualifying offense of murder.

12025–2025
United States v. Sewn Newton green
ca2 · 2004
12025–2025
People v. Fort green
illappct · 2014
1 sentence

2025See, e.g., People v. Wright, 2016 IL App (5th) 120310, ¶ 33 ; Fort, 2014 IL App (1st) 120037, ¶ 19 ; Newton, 369 F.3d at 679 . ¶ 44 In harmless error review, courts may “(1) focus on the error to determine whether it might have contributed to the conviction, (2) examine the other evidence in the case to see if overwhelming evidence supports the conviction, and (3) determine whether the improperly admitted evidence is merely cumulative or duplicates properly admitted evidence.” People v. Salamon, 2022 IL 125722, ¶ 121 . ¶ 45 To convict Rainey of the AHC charge, the State had to prove he (1) eit

12025–2025
People v. Clemons green
ill · 2012
12024–2024
People v. Horne green
illappct · 2023
12023–2023
People v. Barker green
ill · 1980
12020–2020
People v. Stull green
illappct · 2014
12015–2015
People v. Payne green
illappct · 2015
12015–2015
People v. Thomas green
illappct · 2014
12014–2014
People v. Collins green
ill · 1985
11992–1992
People v. Hester green
ill · 1989
11992–1992
People v. Eddington green
illappct · 1984
11986–1986
Felix Stroud Hammontree v. C. Paul Phelps, Director, Louisiana Department of Corrections, Respondent green
ca5 · 1979
11980–1980
People v. Gibson neutral
illappct · 1977
11979–1979

Statutes the citing opinions construe

IL § 725 ILCS 5/110-6.1 (18) IL § 725 ILCS 5/110-5 (8) IL § 720 ILCS 5/12-3.2 (5) IL § 720 ILCS 5/9-1 (4) IL § 725 ILCS 5/110-1.5 (4) IL § 725 ILCS 5/110-10 (4) IL § 725 ILCS 5/110-2 (4) IL § 725 ILCS 5/122-1 (4) IL § 720 ILCS 5/11-1.30 (3) IL § 720 ILCS 5/16-1 (3) IL § 720 ILCS 5/24-1.6 (3) IL § 720 ILCS 570/401 (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 563 (1980–2026) CA 435 (1956–2026) OH 72 (1992–2026) WA 70 (1974–2026) TN 51 (1994–2016) IL 50 (1979–2026) PA 46 (1976–2026) GA 40 (1982–2023) MS 26 (1983–2023) NV 26 (1980–2022) LA 23 (1976–2022) CO 23 (1990–2026) NM 21 (2001–2025) WI 20 (1990–2025) MD 19 (1978–2022) NC 19 (1977–2025) NJ 18 (1989–2025) KS 17 (1993–2026) MI 16 (1971–2022) FL 16 (1970–2026) MN 15 (1978–2024) AL 13 (1994–2012) UT 12 (1983–2025) NY 12 (1971–2026) CT 11 (1991–2020) OR 11 (1977–2025) MO 11 (1983–2021) AZ 10 (1984–2026) OK 9 (1995–2024) VT 9 (1992–2026) IA 8 (1981–2017) VA 7 (1996–2023) NH 7 (1981–2015) SD 7 (1981–2022) AK 7 (1980–2021) IN 6 (1988–2017) DC 6 (1979–2020) MA 5 (1978–2007) WY 5 (2012–2025) NE 5 (1996–2023) RI 5 (1970–2011) MT 4 (1996–2018) HI 4 (1981–2007) KY 4 (2001–2026) VI 3 (2011–2013) AR 2 (2004–2008) ME 2 (1983–2018)

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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