nonevidentiary hearing (Illinois) · Go Syfert
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nonevidentiary hearing in Illinois

6 Illinois opinions name it 2 courts 2014–2026 3 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 (3)

CaseFollowedCited
People v. Pursleygreen
illappct · 2022 · cited in 2 Illinois opinions naming this issue, 2022–2026
2 sentences

2026See People v. Pursley, 2022 IL App (2d) 210558, ¶¶ 57-58 (holding that de novo review did not apply on appeal from the denial of a certificate of innocence where the circuit court only held a nonevidentiary hearing).

2022While the trial court held only a nonevidentiary hearing on Pursley’s petition for a certificate of innocence, it also - 19 - 2022 IL App (2d) 210558 presided over the third-stage postconviction evidentiary hearing and Pursley’s retrial.

12
People v. Avdicgreen
illappct · 2023 · cited in 1 Illinois opinions naming this issue, 2025–2025
1 sentence

2025See People v. Avdic, 2023 IL App (1st) 210848, ¶ 25 (In de novo review we “perform the same analysis that [the circuit court] would.”). ¶ 50 The petitioner’s argument is unpersuasive.

11
Townsend v. Sears, Roebuck and Co.green
ill · 2007 · cited in 1 Illinois opinions naming this issue, 2022–2022
1 sentence

2022The appellants argue that, because the trial court held only a nonevidentiary hearing on Pursley’s petition, the trial court’s decision is subject to de novo review, citing Townsend v. Sears, Roebuck & Co., 227 Ill. 2d 147, 154 (2007) (“Where the circuit court does not hear testimony and bases its decision on documentary evidence, the rationale underlying a deferential standard of review is inapplicable and review is de novo.”). ¶ 58 The appellants’ argument in favor of de novo review is unpersuasive.

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 (2)

CaseCitedYears
People v. Cornelius green
illappct · 2014
2 sentences

2016Petitioner’s motion to reconsider was denied. ¶ 18 Petitioner appealed, and a divided appellate court affirmed the vacating of the tax deed order. 2014 IL App (3d) 130288 .

2015Petitioner’s motion to reconsider was denied. ¶ 18 Petitioner appealed, and a divided appellate court affirmed the vacating of the tax deed order. 2014 IL App (3d) 130288 .

22015–2016
In re Marriage of Shores green
illappct · 2014
1 sentence

2014The agreed order provided that each party would pay for half of each child’s college expenses. -2- 2014 IL App (2d) 130151 ¶7 Regarding the petition to modify child support, the trial court held a nonevidentiary hearing on February 14, 2011.

12014–2014

Statutes the citing opinions construe

IL § 735 ILCS 5/2-702 (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

MA 23 (1991–2026) KS 10 (2007–2024) WI 7 (1999–2025) IL 6 (2014–2026) FL 4 (1981–2017) TX 4 (2005–2022)

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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