state of mind exception (Illinois) · Go Syfert
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state of mind exception in Illinois

50 Illinois opinions name it 2 courts 1976–2025 5 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 (15)

CaseFollowedCited
People v. Floydgreen
ill · 1984 · cited in 9 Illinois opinions naming this issue, 2002–2021
2 sentences

2018This is what makes Rule 403 such an important tool in controlling the admission of evidence and why trial courts are granted vast discretion over evidentiary matters. ¶ 122 The State's assertion is incorrect that Floyd , 103 Ill. 2d 541 , 83 Ill.Dec. 335 , 470 N.E.2d 293 , did not provide the trial court with a basis to exclude the victim's statements that she was afraid of defendant and that "if anything happened to her, defendant did it." Although the State correctly notes that Floyd dealt with the state of mind exception to the rule against hearsay and was decided prior to our supreme court

2018This is what makes Rule 403 such an important tool in controlling the admission of evidence and why trial courts are granted vast discretion over evidentiary matters. ¶ 122 The State's assertion is incorrect that Floyd , 103 Ill. 2d 541 , 83 Ill.Dec. 335 , 470 N.E.2d 293 , did not provide the trial court with a basis to exclude the victim's statements that she was afraid of defendant and that "if anything happened to her, defendant did it." Although the State correctly notes that Floyd dealt with the state of mind exception to the rule against hearsay and was decided prior to our supreme court

59
People v. Munozgreen
illappct · 2010 · cited in 6 Illinois opinions naming this issue, 2011–2020
2 sentences

2020People v. Munoz, 398 Ill.

2014People v. Munoz, 398 Ill.

56
People v. Lawlergreen
ill · 1991 · cited in 6 Illinois opinions naming this issue, 1992–2014
2 sentences

2014Defendant also asserts that the trial court failed to consider Illinois law on the state-of-mind exception when it effectively accepted the authority presented by the State’s motions in limine and failed to consider the seminal cases of People v. Cloutier, 178 Ill. 2d 141 (1997), People v. Lawler, 142 Ill. 2d 548 (1991), and People v. Floyd, 103 Ill. 2d 541 (1984).

1992(People v. Lawler, 142 Ill. 2d at 559 ; People v. Britz (1986), 112 Ill. 2d 314 , 493 N.E.2d 575 .) A statement qualifies under the state of mind exception to the hearsay rule when it purports to relate to a condition of mind existing at the time the statement is made and when it was made under circumstances indicating apparent sincerity.

46
People v. Caffeygreen
ill · 2001 · cited in 4 Illinois opinions naming this issue, 2002–2014
2 sentences

2014See Caffey, 205 Ill. 2d at 91 .

2014See Caffey, 205 Ill. 2d at 91 .

44
People v. Lewisgreen
ill · 2009 · cited in 3 Illinois opinions naming this issue, 2017–2018
2 sentences

2018See People v. Lewis, 234 Ill. 2d 32, 43 (2009) (the defendant carries the burden of persuasion under both prongs of the plain error rule).

2017See People v. Lewis, 234 Ill. 2d 32, 43 (2009) (the defendant carries the burden of persuasion under both prongs of the plain error rule).

33
People v. Cloutiergreen
ill · 1997 · cited in 3 Illinois opinions naming this issue, 2010–2014
2 sentences

2014Defendant also asserts that the trial court failed to consider Illinois law on the state-of-mind exception when it effectively accepted the authority presented by the State’s motions in limine and failed to consider the seminal cases of People v. Cloutier, 178 Ill. 2d 141 (1997), People v. Lawler, 142 Ill. 2d 548 (1991), and People v. Floyd, 103 Ill. 2d 541 (1984).

2014Defendant also asserts that the trial court failed to consider Illinois law on the state-of-mind exception when it effectively accepted the authority presented by the State’s motions in limine and failed to consider the seminal cases of People v. Cloutier, 178 Ill. 2d 141 (1997), People v. Lawler, 142 Ill. 2d 548 (1991), and People v. Floyd, 103 Ill. 2d 541 (1984).

23
People v. Silvestrigreen
illappct · 1986 · cited in 3 Illinois opinions naming this issue, 1995–2002
2 sentences

2002See Silvestri , 148 Ill.

2002See Silvestri, 148 Ill.

23
People v. Colemangreen
illappct · 2002 · cited in 2 Illinois opinions naming this issue, 2004–2004
2 sentences

2004In support, defendant relies on City of Streator v. Industrial Comm'n , 92 Ill. 2d 353, 365 , 442 N.E.2d 497, 503 (1982), where the court upheld the admissibility into evidence, under the state of mind exception to the hearsay rule, of a suicide note stating that the decedent's work-related injury was the cause of his suicide; People v. Coleman , 328 Ill.

2004In support, defendant relies on City of Streator v. Industrial Comm’n, 92 Ill. 2d 353, 365 , 442 N.E.2d 497, 503 (1982), where the court upheld the admissibility into evidence, under the state-of-mind exception to the hearsay rule, of a suicide note stating that the decedent’s work-related injury was the cause of his suicide; People v. Coleman, 328 Ill.

22
City of Streator v. Industrial Commissiongreen
ill · 1982 · cited in 2 Illinois opinions naming this issue, 2004–2004
2 sentences

2004In support, defendant relies on City of Streator v. Industrial Comm’n, 92 Ill. 2d 353, 365 , 442 N.E.2d 497, 503 (1982), where the court upheld the admissibility into evidence, under the state-of-mind exception to the hearsay rule, of a suicide note stating that the decedent’s work-related injury was the cause of his suicide; People v. Coleman, 328 Ill.

2004In support, defendant relies on City of Streator v. Industrial Comm’n, 92 Ill. 2d 353, 365 , 442 N.E.2d 497, 503 (1982), where the court upheld the admissibility into evidence, under the state-of-mind exception to the hearsay rule, of a suicide note stating that the decedent’s work-related injury was the cause of his suicide; People v. Coleman, 328 Ill.

22
Quick v. Michigan Millers Mutual Insurancegreen
illappct · 1969 · cited in 3 Illinois opinions naming this issue, 2004–2014
2 sentences

2014On appeal, the Munoz court determined that the appellate court had “long held that a person’s state of mind ‘may be proved by testimony of contemporaneous oral declarations,’ and expressly rejected the requirement that the declarations be accompanied by a contemporaneous related act.” Id. at 436 (quoting Quick v. Michigan Millers Mutual Insurance Co., 112 Ill.

2004Quick v. Michigan Millers Mutual Insurance Co., 112 Ill.

13
People v. Langgreen
illappct · 1982 · cited in 2 Illinois opinions naming this issue, 2014–2021
2 sentences

2021Id. at 814 . ¶ 48 On appeal, this court held that the victim’s statements were properly admitted under the state of mind exception to the hearsay rule, explaining the statements were “relevant to rebut the defense testimony concerning the marital accord between the defendant and the [victim], to respond to the defendant’s version of how his wife was shot, and to suggest a possible motive for the defendant’s crime.” Id. at 815 .

2021Id. at 814 . ¶ 48 On appeal, this court held that the victim’s statements were properly admitted under the state of mind exception to the hearsay rule, explaining the statements were “relevant to rebut the defense testimony concerning the marital accord between the defendant and the [victim], to respond to the defendant’s version of how his wife was shot, and to suggest a possible motive for the defendant’s crime.” Id. at 815 .

12
GUSKI v. Rajagreen
illappct · 2011 · cited in 1 Illinois opinions naming this issue, 2025–2025
1 sentence

2025“A hearsay statement admitted under the state-of-mind exception may only be used for the limited purpose permitted by the exception, not for its own truth.” Guski v. Raja, 409 Ill.

11
People v. Sargentgreen
ill · 2010 · cited in 1 Illinois opinions naming this issue, 2025–2025
1 sentence

2025See Sargent, 239 Ill. 2d at 189 .

11
People v. Evansgreen
illappct · 2007 · cited in 1 Illinois opinions naming this issue, 2009–2009
1 sentence

2009Hearsay “Hearsay is defined as ‘testimony of an out-of-court statement offered to establish the truth of the matter asserted therein, and resting for its value upon the credibility of the out-of-court asserter.’ ” People v. Evans, 373 Ill.

11
Kapelski v. Alton & Southern Railroadgreen
illappct · 1976 · cited in 1 Illinois opinions naming this issue, 1988–1988
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 (29)

CaseCitedYears
People v. Berry green
illappct · 1988
2 sentences

2002Floyd , 103 Ill. 2d at 546 ; People v. Berry , 172 Ill.

2002Floyd, 103 Ill. 2d at 546 ; People v. Berry, 172 Ill.

41992–2002
People v. Whirl green
illappct · 2015
2 sentences

2019Id. ¶ 77 We find that admissible statements by someone other than petitioner of the intent to commit the very unique crime of arson during the relevant time period is strong evidence of actual innocence, especially in light of the fact that the only evidence against petitioner were his own statements.

2019Id. ¶ 77 We find that admissible statements by someone other than petitioner of the intent to commit the very unique crime of arson during the relevant time period is strong evidence of actual innocence, especially in light of the fact that the only evidence against petitioner were his own statements.

22019–2019
Demons v. State green
ga · 2004
2 sentences

2005In Demons v. State, 277 Ga. 724 , 595 S.E.2d 76 (2004), the Georgia Supreme Court considered whether statements admitted under the necessity exception and the res gestae exception to the hearsay rule violated Crawford.

2005In Demons v. State, 277 Ga. 724 , 595 S.E.2d 76 (2004), the Georgia Supreme Court considered whether statements admitted under the necessity exception and the res gestae exception to the hearsay rule violated Crawford.

22005–2005
People v. Pineda green
illappct · 2004
2 sentences

2004App. 3d 815, 821 , 812 N.E.2d 627 (2004) (holding that declarant must be unavailable for the state of mind exception to apply).

2004App. 3d 815, 821 , 812 N.E.2d 627 (2004) (holding that declarant must be unavailable for the state of mind exception to apply).

22004–2004
People v. Coleman neutral
ill · 2003
2 sentences

2004App. 3d 688, 692 , 767 N.E.2d 388, 392 (2002), vacated on other grounds, 206 Ill. 2d 623 , 799 N.E.2d 677 (2003), where the court upheld the admissibility of the decedent’s out-of-court statements regarding her plan to divorce the defendant — both to establish her state of mind and to suggest the defendant’s motive for killing her 4 ; People v. Ross, 132 Ill.

2004App. 3d 688, 692 , 767 N.E.2d 388, 392 (2002), vacated on other grounds, 206 Ill. 2d 623 , 799 N.E.2d 677 (2003), where the court upheld the admissibility of the decedent’s out-of-court statements regarding her plan to divorce the defendant — both to establish her state of mind and to suggest the defendant’s motive for killing her 4 ; People v. Ross, 132 Ill.

22004–2004
People v. Ross green
illappct · 1985
2 sentences

2004App. 3d 688, 692 , 767 N.E.2d 388, 392 (2002), vacated on other grounds , 206 Ill. 2d 623 , 799 N.E.2d 677 (2003), where the court upheld the admissibility of the decedent's out-of-court statements regarding her plan to divorce the defendant— both to establish her state of mind and to suggest the defendant's motive for killing her (footnote: 4) ; People v. Ross , 132 Ill.

2004App. 3d 688, 692 , 767 N.E.2d 388, 392 (2002), vacated on other grounds, 206 Ill. 2d 623 , 799 N.E.2d 677 (2003), where the court upheld the admissibility of the decedent’s out-of-court statements regarding her plan to divorce the defendant — both to establish her state of mind and to suggest the defendant’s motive for killing her 4 ; People v. Ross, 132 Ill.

22004–2004
People v. Coleman green
illappct · 1983
2 sentences

2002App. 3d 28, 33 , 451 N.E.2d 973 (1983). (footnote: 2) Further, in order for a declarant's out-of-court statement to be admissible under the state-of-mind exception to the hearsay rule, the declarant's state of mind must be relevant to a material issue in the case.

2002App. 3d 28, 33 , 451 N.E.2d 973 (1983). 2 Further, in order for a declarant’s out-of-court statement to be admissible under the state-of-mind exception to the hearsay rule, the declarant’s state of mind must be relevant to a material issue in the case.

22002–2002
People v. Davis green
illappct · 1993
2 sentences

2002Floyd , 103 Ill. 2d at 546 ; People v. Davis , 254 Ill.

2002Floyd, 103 Ill. 2d at 546 ; People v. Davis, 254 Ill.

22002–2002
Enmund v. Florida green
scotus · 1982
2 sentences

1997The State argues that the evidence shows that defendant displayed the victim’s body to Bradford and Halili in an effort to force them to "submit to his wishes.” This, according to the State, shows that in killing the victim defendant acted with the culpable mental state necessary under Enmund v. Florida, 458 U.S. 782 , 73 L.

1997The State argues that the evidence shows that defendant displayed the victim’s body to Bradford and Halili in an effort to force them to "submit to his wishes.” This, according to the State, shows that in killing the victim defendant acted with the culpable mental state necessary under Enmund v. Florida, 458 U.S. 782 , 73 L.

21997–1997
People v. Lynch green
ill · 1984
1 sentence

2024Third, the defendant asserts that the circuit court made the following erroneous evidentiary findings, which impeded his constitutional right to present his defense: (1) prohibiting the introduction of Kendra’s phone call pursuant to the state-of-mind exception to the hearsay doctrine; (2) barring the introduction of Fleming’s prior aggravated assault of a peace officer conviction to show his propensity for violence under Lynch, 104 Ill. 2d 194 , and his UUWF conviction to impeach Robinson, after she testified that she never saw him with a weapon; and (3) permitting the State to introduce inad

12024–2024
In re M.I. green
ill · 2016
1 sentence

2022In its ruling, the circuit court cited to In re M.I., 2016 IL 120232 for the proposition that a parent need not be “at fault” in order for the circuit court to make a finding of failure to make reasonable progress. ¶ 51 In M.I., our supreme court considered whether there was a state of mind requirement regarding a parent’s failure to maintain a reasonable degree of interest in or concern for a child under section 1(D)(b) of the Adoption Act.

12022–2022
People v. Williams green
ill · 1999
2 sentences

2014In Munoz, the trial court found that certain hearsay testimony was not admissible under the state-of-mind exception, based on the concept that “hearsay declarations relating to the contemplation of suicide are generally inadmissible, unless they are part of the ‘res gestae,’ a contemporaneous act of the decedent that such statements might characterize or explain.” Id. at 434 .

2014On appeal, the Munoz court determined that the appellate court had “long held that a person’s state of mind ‘may be proved by testimony of contemporaneous oral declarations,’ and expressly rejected the requirement that the declarations be accompanied by a contemporaneous related act.” Id. at 436 (quoting Quick v. Michigan Millers Mutual Insurance Co., 112 Ill.

12014–2014
People v. Denson green
illappct · 2014
1 sentence

2014Under the state-of-mind exception to the hearsay rule, the rule will not exclude: “A statement of the declarant’s then existing state of mind, emotion, sensation, or physical condition (such as intent, plan, motive, design, mental feeling, pain, and bodily health), but not including: *** -12- 2013 IL App (2d) 110652 (B) a statement of declarant’s then existing state of mind, emotion, sensation, or physical condition to prove the state of mind, emotion, sensation, or physical condition of another declarant at that time or at any other time when such state of the other declarant is an issue in t

12014–2014
People v. Munoz green
illappct · 2004
1 sentence

2009In Munoz, the trial court ruled that certain hearsay testimony was not admissible under the state-of-mind exception, based on the concept that “hearsay declarations relating to the contemplation of suicide are generally inadmissible, unless they are part of the ‘res gestae,’ a contemporaneous act of the decedent that such statements might characterize or explain.” Munoz, 348 Ill.

12009–2009
In Re Marriage of Gustafson green
illappct · 1989
1 sentence

1993In re Marriage of Gustafson (1989), 187 Ill.

11993–1993
Myre v. Kroger Co. green
illappct · 1988
1 sentence

1993App. 3d 160, 167 , 530 N.E.2d 1122, 1126 .) Although not an issue on this appeal, we note that children’s statements as to whom they prefer as a custodian, or where they desire to live, are admissible under the state-of-mind exception to the hearsay rule.

11993–1993
People v. Britz green
ill · 1986
11992–1992
People v. Miller green
illappct · 1983
11991–1991
People v. Jones neutral
illappct · 1980
11989–1989
People v. Olinger green
ill · 1986
11988–1988
Perminas v. Montgomery Ward & Co. green
ill · 1975
11988–1988
The People v. Carpenter green
ill · 1963
11984–1984
People v. Witherspoon neutral
illappct · 1977
11984–1984
United States v. Roland W. Brown green
cadc · 1974
11983–1983
Simon v. Plotkin green
illappct · 1977
11983–1983
People v. Long green
illappct · 1977
11979–1979
People v. Reddock green
illappct · 1973
11979–1979
Commonwealth v. Trainor green
mass · 1978
11978–1978
People v. Thomas green
illappct · 1976
11976–1976

Statutes the citing opinions construe

IL § 720 ILCS 5/9-1 (6) IL § 725 ILCS 5/115-10.1 (6) IL § 735 ILCS 5/8-201 (4) IL § 720 ILCS 5/19-1 (3) IL § 725 ILCS 5/115-12 (3) IL § 730 ILCS 5/5-4.5-25 (3) IL § 730 ILCS 5/5-4.5-35 (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

CA 78 (1968–2026) PA 64 (1971–2026) IL 50 (1976–2025) NY 37 (1983–2024) MA 37 (1982–2025) NC 32 (1977–2016) FL 28 (1984–2025) TX 26 (1971–2024) DC 24 (1978–2023) MO 23 (1983–2025) CT 23 (1980–2020) OH 23 (1993–2025) VA 22 (1989–2025) MD 17 (1981–2024) TN 16 (1994–2019) NJ 16 (1988–2024) IN 14 (1984–2020) WA 12 (1980–2022) CO 11 (1975–2025) OR 11 (1984–2025) AZ 10 (1981–2021) LA 10 (1980–2019) NV 9 (1980–2025) KY 9 (1991–2026) HI 9 (1982–2026) MI 8 (1971–2016) MN 8 (2014–2026) DE 8 (1991–2026) OK 8 (1996–2018) AL 7 (1989–2010) NM 7 (1983–2022) ID 6 (1969–2022) UT 5 (1980–2015) WI 5 (1984–2003) IA 4 (1995–2022) SC 4 (1999–2011) KS 3 (2001–2018) ND 3 (2011–2014) NE 3 (1992–1997) GA 2 (2011–2024) AK 2 (1994–2005) WY 2 (1992–2011) MS 2 (1977–2000)

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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