49 Illinois opinions name it 2 courts 1901–2026 9 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.
| Case | Followed | Cited |
|---|---|---|
People v. Tolefreegreen2 sentences2025See People v. Tolefree, 2011 IL App (1st) 100689, ¶ 23 (“even if an appellate court finds that a trial court made an error, it will not reverse if it finds that the error was harmless”). 2025See People v. Tolefree, 2011 IL App (1st) 100689, ¶ 23 (“even if an appellate court finds that a trial court made an error, it will not reverse if it finds that the error was harmless”). | 2 | 2 |
State v. S. Lehrkampgreen2 sentences2019See State v. Lehrkamp, 2017 MT 203, ¶ 11 , 400 P.3d 697 (review of the legality of a sentence is confined to determining whether the sentencing court had statutory authority to impose the sentence). ¶ 51 The State also notes that here, unlike in Foster, defendant’s original sentence was not increased by the court’s order reconsidering its ruling on defendant’s motion to reconsider. 2019See State v. Lehrkamp, 2017 MT 203, ¶ 11 , 400 P.3d 697 (review of the legality of a sentence is confined to determining whether the sentencing court had statutory authority to impose the sentence). ¶ 51 The State also notes that here, unlike in Foster, defendant’s original sentence was not increased by the court’s order reconsidering its ruling on defendant’s motion to reconsider. | 2 | 2 |
Hale v. Gibsongreen2 sentences2011See United States v. Adelzo-Gonzalez, 268 F.3d 772, 778-79 (9th Cir. 2001) (holding that the defendant completely lost trust in his attorney with legitimate reason where the attorney threatened the defendant that he would “ ‘sink him for 105 years’ ” and testify against him; called the defendant a liar; and openly opposed the defendant’s motions for substitution); United States v. Nguyen, 262 F.3d 998, 1003-04 (9th Cir. 2001) (where the defendant’s counsel of choice appeared and requested leave to be substituted in for the public defender and requested a continuance and the trial court made no 2011See United States v. Adelzo-Gonzalez, 268 F.3d 772, 778-79 (9th Cir.2001) (holding that the defendant completely lost trust in his attorney with legitimate reason where the attorney threatened the defendant that he would "`sink him for 105 years'" and testify against him; called the defendant a liar; and openly opposed the defendant's motions for substitution); United States v. Nguyen, 262 F.3d 998, 1003-04 (9th Cir.2001) (where the defendant's counsel of choice appeared and requested leave to be substituted in for the public defender and requested a continuance and the trial court made no inq | 2 | 2 |
Beehn v. Eppardgreen2 sentences2011See Beehn v. Eppard, 321 Ill. 2011See Beehn v. Eppard, 321 Ill. | 2 | 2 |
Ben Lee Brown v. Walter E. Cravengreen2 sentences2011See United States v. Adelzo-Gonzalez, 268 F.3d 772, 778-79 (9th Cir. 2001) (holding that the defendant completely lost trust in his attorney with legitimate reason where the attorney threatened the defendant that he would “ ‘sink him for 105 years’ ” and testify against him; called the defendant a liar; and openly opposed the defendant’s motions for substitution); United States v. Nguyen, 262 F.3d 998, 1003-04 (9th Cir. 2001) (where the defendant’s counsel of choice appeared and requested leave to be substituted in for the public defender and requested a continuance and the trial court made no 2011See United States v. Adelzo-Gonzalez, 268 F.3d 772, 778-79 (9th Cir.2001) (holding that the defendant completely lost trust in his attorney with legitimate reason where the attorney threatened the defendant that he would "`sink him for 105 years'" and testify against him; called the defendant a liar; and openly opposed the defendant's motions for substitution); United States v. Nguyen, 262 F.3d 998, 1003-04 (9th Cir.2001) (where the defendant's counsel of choice appeared and requested leave to be substituted in for the public defender and requested a continuance and the trial court made no inq | 2 | 2 |
United States v. Carlos Adelzo-Gonzalezgreen2 sentences2011See United States v. Adelzo-Gonzalez, 268 F.3d 772, 778-79 (9th Cir. 2001) (holding that the defendant completely lost trust in his attorney with legitimate reason where the attorney threatened the defendant that he would “ ‘sink him for 105 years’ ” and testify against him; called the defendant a liar; and openly opposed the defendant’s motions for substitution); United States v. Nguyen, 262 F.3d 998, 1003-04 (9th Cir. 2001) (where the defendant’s counsel of choice appeared and requested leave to be substituted in for the public defender and requested a continuance and the trial court made no 2011See United States v. Adelzo-Gonzalez, 268 F.3d 772, 778-79 (9th Cir.2001) (holding that the defendant completely lost trust in his attorney with legitimate reason where the attorney threatened the defendant that he would "`sink him for 105 years'" and testify against him; called the defendant a liar; and openly opposed the defendant's motions for substitution); United States v. Nguyen, 262 F.3d 998, 1003-04 (9th Cir.2001) (where the defendant's counsel of choice appeared and requested leave to be substituted in for the public defender and requested a continuance and the trial court made no inq | 2 | 2 |
United States v. Trung Tran Nguyengreen2 sentences2011See United States v. Adelzo-Gonzalez, 268 F.3d 772, 778-79 (9th Cir. 2001) (holding that the defendant completely lost trust in his attorney with legitimate reason where the attorney threatened the defendant that he would “ ‘sink him for 105 years’ ” and testify against him; called the defendant a liar; and openly opposed the defendant’s motions for substitution); United States v. Nguyen, 262 F.3d 998, 1003-04 (9th Cir. 2001) (where the defendant’s counsel of choice appeared and requested leave to be substituted in for the public defender and requested a continuance and the trial court made no 2011See United States v. Adelzo-Gonzalez, 268 F.3d 772, 778-79 (9th Cir.2001) (holding that the defendant completely lost trust in his attorney with legitimate reason where the attorney threatened the defendant that he would "`sink him for 105 years'" and testify against him; called the defendant a liar; and openly opposed the defendant's motions for substitution); United States v. Nguyen, 262 F.3d 998, 1003-04 (9th Cir.2001) (where the defendant's counsel of choice appeared and requested leave to be substituted in for the public defender and requested a continuance and the trial court made no inq | 2 | 2 |
Weidner v. Midcon Corp.green2 sentences2007See Weidner v. Midcon Corp., 328 Ill.App.3d 1056, 1061 , 263 Ill.Dec. 89 , 767 N.E.2d 815 (2002). 2007See Weidner v. Midcon Corp., 328 Ill.App.3d 1056, 1061 , 263 Ill.Dec. 89 , 767 N.E.2d 815 (2002). | 2 | 2 |
City of Elgin v. County of Cookgreen2 sentences2006See City of Elgin, 169 Ill. 2d at 72 ; Firestone, 119 Ill. 2006See City of Elgin, 169 Ill. 2d at 72 ; Firestone, 119 Ill. | 2 | 2 |
People v. Rameygreen2 sentences2011People v. Ramey, 152 Ill.2d 41, 52 , 178 Ill.Dec. 19 , 604 N.E.2d 275 (1992); Moore, 207 Ill.2d at 78 , 278 Ill.Dec. 36 , 797 N.E.2d 631 ; Chapman, 194 Ill.2d at 230 , 252 Ill.Dec. 474 , 743 N.E.2d 48 ; Johnson, 159 Ill.2d at 124 , 201 Ill.Dec. 53 , 636 N.E.2d 485 . ¶ 23 On review, even if an appellate court finds that a trial court made an error, it will not reverse if it finds that the error was harmless. 2011People v. Ramey, 152 Ill.2d 41, 52 , 178 Ill.Dec. 19 , 604 N.E.2d 275 (1992); Moore, 207 Ill.2d at 78 , 278 Ill.Dec. 36 , 797 N.E.2d 631 ; Chapman, 194 Ill.2d at 230 , 252 Ill.Dec. 474 , 743 N.E.2d 48 ; Johnson, 159 Ill.2d at 124 , 201 Ill.Dec. 53 , 636 N.E.2d 485 . ¶ 23 On review, even if an appellate court finds that a trial court made an error, it will not reverse if it finds that the error was harmless. | 1 | 2 |
People v. Enochgreen1 sentence2026People v. Enoch, 122 Ill. 2d 176, 186 (1988). | 1 | 1 |
People v. Johnsongreen1 sentence2025Instead, the court properly relied “on a PSI to establish the existence of a prior conviction for purposes of imposing an extended-term sentence under section 5-5-3.2(b)(1) [of the Unified Code].” People v. Johnson, 372 Ill. | 1 | 1 |
People v. Jenkinsgreen2 sentences2024See People v. Jenkins, 2020 IL App (1st) 172422, ¶ 16 (“The trial court made no inquiry into how long [counsel] required to prepare for trial ***.”). 2024See People v. Jenkins, 2020 IL App (1st) 172422, ¶ 16 (“The trial court made no inquiry into how long [counsel] required to prepare for trial ***.”). | 1 | 1 |
People v. Skillomgreen1 sentence2022People v. Tolefree, 2011 IL App (1st) 100689, ¶ 29 (holding that the trial court’s failure to conduct a preliminary Krankel inquiry was harmless error); see People v. Skillom, 2017 IL App (2d) 150681, ¶ 28 (noting that our supreme court has never held that errors committed during a preliminary Krankel hearing could never be subject to harmless-error review). ¶ 63 In the present case, we hold that the trial court’s failure to conduct a preliminary Krankel inquiry was harmless error. | 1 | 1 |
In Re Marriage of Gulla and Kanavalgreen1 sentence2020In re Marriage of Gulla and Kanaval, 234 Ill. 2d 414, 422 (2009). | 1 | 1 |
| People v. Krankelgreen | 1 | 1 |
| People v. Jacksongreen | 1 | 1 |
| People v. Morgangreen | 1 | 1 |
| People v. Davisgreen | 1 | 1 |
| Rippon v. Rippongreen | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Illinois. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
People v. Moore
green
2 sentences2013The court made no inquiry into the allegation of ineffective assistance and the issue was not raised again. ¶ 63 Arsenio contends the court's conduct in the face of defense counsel's allegation failed to satisfy the preliminary requirement of Krankel and People v. Moore, 207 Ill. 2d 68 (2003), and, therefore, asks this court to remand for appointment of counsel and a full inquiry into the allegation of ineffective assistance of counsel. 2013The court made no inquiry into the allegation of ineffective assistance and the issue was not raised again. ¶ 63 Arsenio contends the court’s conduct in the face of defense counsel’s allegation failed to satisfy the preliminary requirement of Krankel and People v. Moore, 207 Ill. 2d 68 (2003), and, therefore, asks this court to remand for appointment of counsel and a full inquiry into the allegation of ineffective assistance of counsel. | 10 | 2009–2018 |
People v. Nitz
green
2 sentences2011Moore, 207 Ill.2d at 80 , 278 Ill.Dec. 36 , 797 N.E.2d 631 ; Nitz, 143 Ill.2d at 135 , 157 Ill.Dec. 431 , 572 N.E.2d 895 . 2011Moore, 207 Ill.2d at 80 , 278 Ill.Dec. 36 , 797 N.E.2d 631 ; Nitz, 143 Ill.2d at 135 , 157 Ill.Dec. 431 , 572 N.E.2d 895 . | 3 | 2009–2011 |
People v. Adams
green
2 sentences2021The trial court made no inquiry into how long Johnson required to prepare for trial, defendant’s reasons for wanting new counsel, the efforts Jenkins made to retain private counsel and when, or whether he had been cooperative with his assistant public defender. “[T]his failure by itself would justify reversal.” Adams, 2016 IL App (1st) 141135, ¶ 17 . 2020The trial court made no inquiry into how long Johnson required to prepare for trial, defendant’s reasons for wanting new counsel, the efforts Jenkins made to retain private counsel and when, or whether he had been cooperative with his assistant public defender. “[T]his failure by itself would justify reversal.” Adams, 2016 IL App (1st) 141135, ¶ 17 . | 2 | 2020–2021 |
Macknin v. Macknin
green
2 sentences2020Id. ¶ 31 Our primary task is to determine the scope of the trial court’s authority to disqualify the Public Defender based on the governing statutes and court rules. 2020Id. ¶ 31 Our primary task is to determine the scope of the trial court’s authority to disqualify the Public Defender based on the governing statutes and court rules. | 2 | 2020–2020 |
People v. Johnson
green
2 sentences2011People v. Ramey, 152 Ill.2d 41, 52 , 178 Ill.Dec. 19 , 604 N.E.2d 275 (1992); Moore, 207 Ill.2d at 78 , 278 Ill.Dec. 36 , 797 N.E.2d 631 ; Chapman, 194 Ill.2d at 230 , 252 Ill.Dec. 474 , 743 N.E.2d 48 ; Johnson, 159 Ill.2d at 124 , 201 Ill.Dec. 53 , 636 N.E.2d 485 . ¶ 23 On review, even if an appellate court finds that a trial court made an error, it will not reverse if it finds that the error was harmless. 2011People v. Ramey, 152 Ill.2d 41, 52 , 178 Ill.Dec. 19 , 604 N.E.2d 275 (1992); Moore, 207 Ill.2d at 78 , 278 Ill.Dec. 36 , 797 N.E.2d 631 ; Chapman, 194 Ill.2d at 230 , 252 Ill.Dec. 474 , 743 N.E.2d 48 ; Johnson, 159 Ill.2d at 124 , 201 Ill.Dec. 53 , 636 N.E.2d 485 . ¶ 23 On review, even if an appellate court finds that a trial court made an error, it will not reverse if it finds that the error was harmless. | 2 | 2011–2011 |
People v. Chapman
green
2 sentences2011People v. Ramey, 152 Ill.2d 41, 52 , 178 Ill.Dec. 19 , 604 N.E.2d 275 (1992); Moore, 207 Ill.2d at 78 , 278 Ill.Dec. 36 , 797 N.E.2d 631 ; Chapman, 194 Ill.2d at 230 , 252 Ill.Dec. 474 , 743 N.E.2d 48 ; Johnson, 159 Ill.2d at 124 , 201 Ill.Dec. 53 , 636 N.E.2d 485 . ¶ 23 On review, even if an appellate court finds that a trial court made an error, it will not reverse if it finds that the error was harmless. 2011People v. Ramey, 152 Ill.2d 41, 52 , 178 Ill.Dec. 19 , 604 N.E.2d 275 (1992); Moore, 207 Ill.2d at 78 , 278 Ill.Dec. 36 , 797 N.E.2d 631 ; Chapman, 194 Ill.2d at 230 , 252 Ill.Dec. 474 , 743 N.E.2d 48 ; Johnson, 159 Ill.2d at 124 , 201 Ill.Dec. 53 , 636 N.E.2d 485 . ¶ 23 On review, even if an appellate court finds that a trial court made an error, it will not reverse if it finds that the error was harmless. | 2 | 2011–2011 |
Firestone v. Fritz
green
2 sentences2006See City of Elgin, 169 Ill. 2d at 72 ; Firestone, 119 Ill. 2006See City of Elgin, 169 Ill. 2d at 72 ; Firestone, 119 Ill. | 2 | 2006–2006 |
The People v. Bush
green
2 sentences1974It is also apparent from the record that the passing reference to the right to counsel, made at the time this plea was taken on February 28,1967, may be characterized as the sort of routine inquiry’ proscribed in People v. Bush, 32 Ill.2d 484 , 207 N.E.2d 446 , where the court said with reference to right to counsel ‘a finding of waiver is not lightly to be made [Citations] and the record must show that an accused was offered counsel and that he intelligently and understandingly rejected the offer. [Citations.] In order that the court may be sure that an accused fully understands his right to 1974It is also apparent from the record that the passing reference to the right to counsel, made at the time this plea was taken on February 28,1967, may be characterized as the sort of routine inquiry’ proscribed in People v. Bush, 32 Ill.2d 484 , 207 N.E.2d 446 , where the court said with reference to right to counsel ‘a finding of waiver is not lightly to be made [Citations] and the record must show that an accused was offered counsel and that he intelligently and understandingly rejected the offer. [Citations.] In order that the court may be sure that an accused fully understands his right to | 2 | 1973–1974 |
The People v. Hessenauer
green
2 sentences1974It is also apparent from the record that the passing reference to the right to counsel, made at the time this plea was taken on February 28,1967, may be characterized as the sort of routine inquiry’ proscribed in People v. Bush, 32 Ill.2d 484 , 207 N.E.2d 446 , where the court said with reference to right to counsel ‘a finding of waiver is not lightly to be made [Citations] and the record must show that an accused was offered counsel and that he intelligently and understandingly rejected the offer. [Citations.] In order that the court may be sure that an accused fully understands his right to 1974It is also apparent from the record that the passing reference to the right to counsel, made at the time this plea was taken on February 28,1967, may be characterized as the sort of routine inquiry’ proscribed in People v. Bush, 32 Ill.2d 484 , 207 N.E.2d 446 , where the court said with reference to right to counsel ‘a finding of waiver is not lightly to be made [Citations] and the record must show that an accused was offered counsel and that he intelligently and understandingly rejected the offer. [Citations.] In order that the court may be sure that an accused fully understands his right to | 2 | 1973–1974 |
People v. Curry
green
1 sentence2026Defendant, unhappy with his appointed counsel’s performance, requested the court delay proceeding until he “[got his] settlement in so [he could] get private counsel.” Defendant believed he would receive his settlement money within “the next three weeks to a month.” Defendant did not identify who he was seeking as substitute counsel, and when asked if substitute counsel was “retained or prepared to enter this week,” defendant answered, “No.” As such, defendant did not have a substitute counsel “ready, willing, and able to make an unconditional entry of appearance.” (Internal quotation marks om | 1 | 2026–2026 |
Taylor v. County of Cook
green
1 sentence2025“A circuit court’s evidentiary rulings regarding the admissibility of testimony and on a motion in limine are within its sound discretion and this court will not reverse such rulings unless the circuit court abused its discretion.” Taylor v. County of Cook, 2011 IL App (1st) 093085, ¶ 23 . | 1 | 2025–2025 |
Mathis v. United States
green
1 sentence2025The court made no inquiry into the “manner in which the defendant committed that offense.” Mathis v. United States, 579 U.S. 500 , 511 (2016). | 1 | 2025–2025 |
Sanders v. Oakbrook Healthcare Centre, Ltd.
green
1 sentence2023Sanders, 2022 IL App (1st) 221347, ¶ 15 . | 1 | 2023–2023 |
People v. Pecoraro
green
1 sentence2020Pecoraro is wholly inapposite to the case at bar where here, the trial court made no inquiry whatsoever into defendant’s allegations of ineffective assistance of counsel. ¶ 43 Our supreme court in Pecoraro stated that the trial court was not required to conduct a Krankel inquiry into allegations of ineffective assistance of counsel directed at private counsel. 12 No. 1-18-1466 In so holding, the supreme court stated that the “defendant and his counsel were the only parties who could have altered their attorney-client relationship.” Id. at 15 . | 1 | 2020–2020 |
Foutch v. O'BRYANT
green
1 sentence2020Id. ¶ 31 To determine whether the trial court made the error which appellant is claiming, a court of review must have before it the record of the proceedings where the error was allegedly made. | 1 | 2020–2020 |
| People v. Wilkins green | 1 | 2018–2018 |
| People v. McDonald green | 1 | 2016–2016 |
| People v. Rathbone green | 1 | 2015–2015 |
| The PEOPLE v. Nelson green | 1 | 1992–1992 |
| Jarrett v. Jarrett green | 1 | 1983–1983 |
| People v. Morgese green | 1 | 1982–1982 |
| Korsgaard v. Elliott green | 1 | 1979–1979 |
| People v. Slaten green | 1 | 1975–1975 |
| People v. Melvin green | 1 | 1975–1975 |
| People v. Garcia neutral | 1 | 1973–1973 |
| People v. Trobiani neutral | 1 | 1960–1960 |
| May v. Keep neutral | 1 | 1901–1901 |
| Hurlbut v. Wilcox neutral | 1 | 1901–1901 |
| State ex rel. Board of Education v. Haben neutral | 1 | 1901–1901 |
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.
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.