47 Illinois opinions name it 2 courts 1990–2025 4 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 |
|---|---|---|
United States v. Sokolowgreen2 sentences2021We noted in Gates, 462 U. S., at 243-244, n. 13 , - 14 - that ‘innocent behavior will frequently provide the basis for a showing of probable cause,’ and that ‘[i]n making a determination of probable cause the relevant inquiry is not whether particular conduct is “innocent” or “guilty,” but the degree of suspicion that attaches to particular types of noncriminal acts.’ That principle applies equally well to the reasonable suspicion inquiry.” United States v. Sokolow, 490 U.S. 1, 9 (1989). 2016Id. at 124 , see also United States v. Brignoni-Ponce, 422 U.S. 873, 885 (1975) (a driver’s obvious attempts to evade officers is an appropriate factor in deciding reasonable suspicion); Florida v. Rodriguez, 469 U.S. 1, 6 (1984) (a person’s “strange movements” in his attempt to evade police officers contributed to a finding of reasonable suspicion); United States v. Sokolow, 490 U.S. 1, 8 (1989) (a person’s evasive route through an airport -6- can be highly probative in a reasonable suspicion analysis). | 4 | 6 |
United States v. Cortezgreen2 sentences2021The “totality of the circumstances—the whole picture” (Cortez, 449 U.S. at 417 ) showed that the police were notified of a call placed through the 911 system from someone who appeared to be witnessing an assault in progress by an armed perpetrator. 2020Kansas v. Glover, 589 U.S. ___ , ___, 140 S. Ct. 1183, 1187 (2020) (“[T]he Fourth Amendment permits an officer to initiate a brief investigative traffic stop when he has ‘a particularized and objective basis for suspecting the particular person stopped of criminal activity.’ ” (quoting United States v. Cortez, 449 U.S. 411, 417-18 (1981))). | 4 | 5 |
Commonwealth v. Mercadogreen2 sentences2017See Commonwealth v. Mercado, 422 Mass. 367, 371 (1996) (“Neither evasive behavior, proximity to a crime scene, nor matching a general description is alone sufficient to support *** reasonable suspicion”); Commonwealth v. Thibeau, 384 Mass. 762, 764 (1981) (quick maneuver to avoid contact with police insufficient to establish reasonable suspicion). 2017See Commonwealth v. Mercado, 663 N.E.2d 243, 246 (Mass. 1996) (“Neither evasive behavior, proximity to a crime scene, nor matching a general description is alone sufficient to support *** reasonable suspicion.”); Commonwealth v. Thibeau, 429 N.E.2d 1009, 1010 (Mass. 1981) (quick maneuver to avoid contact with police insufficient to establish reasonable suspicion). | 4 | 4 |
Commonwealth v. Thibeaugreen2 sentences2017See Commonwealth v. Mercado, 422 Mass. 367, 371 (1996) (“Neither evasive behavior, proximity to a crime scene, nor matching a general description is alone sufficient to support *** reasonable suspicion”); Commonwealth v. Thibeau, 384 Mass. 762, 764 (1981) (quick maneuver to avoid contact with police insufficient to establish reasonable suspicion). 2017See Commonwealth v. Mercado, 663 N.E.2d 243, 246 (Mass. 1996) (“Neither evasive behavior, proximity to a crime scene, nor matching a general description is alone sufficient to support *** reasonable suspicion.”); Commonwealth v. Thibeau, 429 N.E.2d 1009, 1010 (Mass. 1981) (quick maneuver to avoid contact with police insufficient to establish reasonable suspicion). | 4 | 4 |
People v. Lampitokgreen2 sentences2008See Lampitok, 207 Ill. 2d at 252 (imposing a reasonable suspicion requirement on probation officers even where probation agreement contained no such requirement); cf. People v. Wilson, 228 Ill. 2d 35, 52 (2008) (finding that the fourth amendment does not prohibit a police officer from conducting a suspicionless search of a parolee where parole agreement contains no limit on searches of parolee's person, property, or residence but recognizing a distinction between probationers and parolees; parolees enjoy a much lesser expectation of privacy than probationers because they pose a higher risk to 2008See Lampitok, 207 Ill. 2d at 252 (imposing a reasonable suspicion requirement on probation officers even where probation agreement contained no such requirement); cf. People v. Wilson, 228 Ill. 2d 35, 52 (2008) (finding that the fourth amendment does not prohibit a police officer from conducting a suspicionless search of a parolee where parole agreement contains no limit on searches of parolee’s person, property, or residence but recognizing a distinction between probationers and parolees; parolees enjoy a much lesser expectation of privacy than probationers because they pose a higher risk to | 4 | 4 |
People v. Timmsengreen2 sentences2023“Evasive behavior and a person’s refusal to speak with an officer when an officer approaches him are not one and the same.” Timmsen, 2016 IL 118181, ¶ 15 (the defendant’s U-turn upon encountering a police roadblock was the opposite of going about his business and constituted evasive behavior to be considered as one of the circumstances contributing to a reasonable suspicion analysis). ¶ 17 The defendant primarily relies on two cases. 2021See also Timmsen, 2016 IL 118181, ¶ 44 (Thomas J., specially concurring) (noting that, in a reasonable suspicion analysis, the behavior the police observe will not be obviously illegal; if they observed obviously illegal activity, then the probable cause standard would be met). ¶ 35 For all the above reasons, we agree with the lower courts that no fourth amendment violation occurred. | 2 | 5 |
People v. Ertlgreen2 sentences2004People v. Ertl , 292 Ill. 2004People v. Ertl, 292 Ill. | 2 | 4 |
Kansas v. Glovergreen2 sentences2020The Court echoed the long-standing principle that the reasonable suspicion standard sets a lower bar than either the probable cause or preponderance of the evidence standards, instructing, “[t]he reasonable suspicion inquiry ‘falls considerably short’ of 51% accuracy -8- [citation] for, as we have explained, ‘to be reasonable is not to be perfect.’ [Citation.]” Glover, 589 U.S. at ___, 140 S. Ct. at 1188 . ¶ 23 Heeding the Court’s guidance, we turn to the case before us. 2020The Court echoed the long-standing principle that the reasonable suspicion standard sets a lower bar than either the probable cause or preponderance of the evidence standards, instructing, “[t]he reasonable suspicion inquiry ‘falls considerably short’ of 51% accuracy [citation] for, as we have explained, ‘to be reasonable is not to be perfect.’ [Citation.]” Glover, 589 U.S. at ___, 140 S. Ct. at 1188 . ¶ 23 Heeding the Court’s guidance, we turn to the case before us. | 2 | 2 |
Hoffman v. Board of Fire & Police Commissionersgreen2 sentences2015Hoffman v. Board of Fire & Police Commissioners, 175 Ill. 2015Hoffman v. Board of Fire & Police Commissioners, 175 Ill. | 2 | 2 |
Liberal v. Estradagreen2 sentences2013Id. at 1079 (“The first Terry condition was not met in this case; the traffic stop was unlawful because it did not rest on a reasonable suspicion that a violation of law had occurred. 2013Id. at 1079 (“The first Terry condition was not met in this case; the traffic stop was unlawful because it did not rest on a reasonable suspicion that a violation of law had occurred. | 2 | 2 |
People v. Wilsongreen2 sentences2008See Lampitok, 207 Ill. 2d at 252 (imposing a reasonable suspicion requirement on probation officers even where probation agreement contained no such requirement); cf. People v. Wilson, 228 Ill. 2d 35, 52 (2008) (finding that the fourth amendment does not prohibit a police officer from conducting a suspicionless search of a parolee where parole agreement contains no limit on searches of parolee's person, property, or residence but recognizing a distinction between probationers and parolees; parolees enjoy a much lesser expectation of privacy than probationers because they pose a higher risk to 2008See Lampitok, 207 Ill. 2d at 252 (imposing a reasonable suspicion requirement on probation officers even where probation agreement contained no such requirement); cf. People v. Wilson, 228 Ill. 2d 35, 52 (2008) (finding that the fourth amendment does not prohibit a police officer from conducting a suspicionless search of a parolee where parole agreement contains no limit on searches of parolee’s person, property, or residence but recognizing a distinction between probationers and parolees; parolees enjoy a much lesser expectation of privacy than probationers because they pose a higher risk to | 2 | 2 |
United States v. Jeffrey Clark Vincentgreen2 sentences2003See, e.g., United States v. Vincent, 167 F.3d 428, 431 (8th Cir. 1999) (probation search is permissible, even if probation condition is overbroad, if the search authority is “narrowly and properly exercised”). 2003See, e.g., United States v. Vincent, 167 F.3d 428, 431 (8th Cir.1999) (probation search is permissible, even if probation condition is overbroad, if the search authority is "narrowly and properly exercised"). | 2 | 2 |
Illinois v. Wardlowgreen2 sentences2025People v. Salgado, 2019 IL App (1st) 171377, ¶ 31 (citing Illinois v. Wardlow, 528 U.S. 119, 124 (2000)). 2016Id. at 124 , see also United States v. Brignoni-Ponce, 422 U.S. 873, 885 (1975) (a driver’s obvious attempts to evade officers is an appropriate factor in deciding reasonable suspicion); Florida v. Rodriguez, 469 U.S. 1, 6 (1984) (a person’s “strange movements” in his attempt to evade police officers contributed to a finding of reasonable suspicion); United States v. Sokolow, 490 U.S. 1, 8 (1989) (a person’s evasive route through an airport -6- can be highly probative in a reasonable suspicion analysis). | 1 | 2 |
People v. Magallanesgreen2 sentences2018Pursuant to the reasonable suspicion standard, "[t]o *916 justify a Terry stop, an officer 'must be able to point to specific and articulable facts which, taken together with rational inferences from those facts, reasonably warrant [the] intrusion.' " People v. Magallanes , 409 Ill. 2018Pursuant to the reasonable suspicion standard, “[t]o justify a Terry stop, an officer ‘must be able to point to specific and articulable facts which, taken together with rational inferences from those facts, reasonably warrant [the] intrusion.’ ” People v. Magallanes, 409 Ill. | 1 | 2 |
People v. Colyargreen2 sentences2018Colyar , 2013 IL 111835 , ¶ 33, 374 Ill.Dec. 880 , 996 N.E.2d 575 (citing Terry , 392 U.S. at 10 -12 , 88 S.Ct. 1868 ). 2018Colyar , 2013 IL 111835 , ¶ 33, 374 Ill.Dec. 880 , 996 N.E.2d 575 (citing Terry , 392 U.S. at 10 -12 , 88 S.Ct. 1868 ). | 1 | 2 |
People v. Salgadogreen1 sentence2025People v. Salgado, 2019 IL App (1st) 171377, ¶ 31 (citing Illinois v. Wardlow, 528 U.S. 119, 124 (2000)). | 1 | 1 |
Prado Navarette v. Californiagreen1 sentence2023Navarette v. California, 572 U.S. 393, 396 (2014). | 1 | 1 |
Illinois v. Gatesgreen1 sentence2021We noted in Gates, 462 U. S., at 243-244, n. 13 , - 14 - that ‘innocent behavior will frequently provide the basis for a showing of probable cause,’ and that ‘[i]n making a determination of probable cause the relevant inquiry is not whether particular conduct is “innocent” or “guilty,” but the degree of suspicion that attaches to particular types of noncriminal acts.’ That principle applies equally well to the reasonable suspicion inquiry.” United States v. Sokolow, 490 U.S. 1, 9 (1989). | 1 | 1 |
| United States v. Arvizugreen | 1 | 1 |
| United States v. Brignoni-Poncegreen | 1 | 1 |
| Florida v. Rodriguezgreen | 1 | 1 |
| Henness v. Bagleygreen | 1 | 1 |
| United States v. Torresgreen | 1 | 1 |
| Coronado v. Stategreen | 1 | 1 |
| Picha v. Wielgosgreen | 1 | 1 |
| Coronado v. Stategreen | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Illinois. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Commonwealth v. Warren
green
2 sentences2017The Warren court continued, “Second, *** where the suspect is a black male stopped by the police on the streets of Boston, the analysis of flight as a factor in the reasonable suspicion calculus cannot be divorced from the findings in a recent [Boston police department] report documenting a pattern of racial profiling of black males in the city of Boston.” Id. at 539 . ¶ 73 Recognizing a defendant’s evasive conduct during an encounter with police to be one factor to consider in the reasonable suspicion analysis, the Warren court cautioned against deeming this fact alone sufficient to establish 2017The Warren court continued, “Second, *** where the suspect is a black male stopped by the police on the streets of Boston, the analysis of flight as a factor in the reasonable suspicion calculus cannot be divorced from the findings in a recent Boston Police Department *** report documenting a pattern of racial profiling of black males in the city of Boston.” Id. at 342 . ¶ 75 Recognizing a defendant’s evasive conduct during an encounter with police to be one factor to consider in the reasonable suspicion analysis, the Warren court cautioned against -23- 1-14-2019 deeming this fact alone suffic | 5 | 2017–2019 |
Terry v. Ohio
green
2 sentences1993The reasonable suspicion standard first emerged in Terry v. Ohio (1968), 392 U.S. 1 , 20 L. 1993The reasonable suspicion standard first emerged in Terry v. Ohio (1968), 392 U.S. 1 , 20 L. | 3 | 1993–2018 |
New Jersey v. T. L. O.
green
2 sentences1996Noting that the school staff must deal with difficult students, the court held that the proper fourth amendment standard to apply in this case was the reasonable suspicion standard for searches of students by school officials (New Jersey v. T.L.O. (1985), 469 U.S. 325 , 83 L. 1996Noting that the school staff must deal with difficult students, the court held that the proper fourth amendment standard to apply in this case was the reasonable suspicion standard for searches of students by school officials (New Jersey v. T.L.O. (1985), 469 U.S. 325 , 83 L. | 3 | 1996–2005 |
People v. Dilworth
green
2 sentences1996The majority attempts to find support for its holding by stating that the reasonable suspicion standard applies in those cases "involving school police or liaison officers." ( 169 Ill.2d at 207 , 214 Ill.Dec. at 463 , 661 N.E.2d at 317 .) The two decisions on which the majority relies for this assertion, however, Wilcher v. State (Tex.Ct.App.1994), 876 S.W.2d 466 , and In re S.F. (1992), 414 Pa.Super. 529 , 607 A.2d 793 , not only fail to address the issue of what fourth amendment standard applies, they do not involve police liaison officers. 1996The majority attempts to find support for its holding by stating that the reasonable suspicion standard applies in those cases "involving school police or liaison officers." ( 169 Ill.2d at 207 , 214 Ill.Dec. at 463 , 661 N.E.2d at 317 .) The two decisions on which the majority relies for this assertion, however, Wilcher v. State (Tex.Ct.App.1994), 876 S.W.2d 466 , and In re S.F. (1992), 414 Pa.Super. 529 , 607 A.2d 793 , not only fail to address the issue of what fourth amendment standard applies, they do not involve police liaison officers. | 3 | 1996–2003 |
People v. Maxey
green
2 sentences2018People v. Maxey, 2011 IL App (1st) 100011, ¶ 46 . 2018People v. Maxey , 2011 IL App (1st) 100011 , ¶ 46, 350 Ill.Dec. 963 , 949 N.E.2d 755 . | 2 | 2018–2018 |
People v. Simpson
green
2 sentences2018In order to justify a stop, "the officer must point to specific, articulable facts which, when considered with natural inferences, make the intrusion reasonable." People v. Simpson , 2015 IL App (1st) 130303 , ¶ 23, 390 Ill.Dec. 614 , 29 N.E.3d 546 . ¶ 15 Under this reasonable suspicion standard, the facts necessary to justify a Terry stop do not need to rise to the level of probable cause and can be satisfied even if no violation of the law is observed, but the facts must go beyond a mere hunch. 2018In order to justify a stop, "the officer must point to specific, articulable facts which, when considered with natural inferences, make the intrusion reasonable." People v. Simpson , 2015 IL App (1st) 130303 , ¶ 23, 390 Ill.Dec. 614 , 29 N.E.3d 546 . ¶ 15 Under this reasonable suspicion standard, the facts necessary to justify a Terry stop do not need to rise to the level of probable cause and can be satisfied even if no violation of the law is observed, but the facts must go beyond a mere hunch. | 2 | 2018–2018 |
State v. Lichty
green
2 sentences2017The Oregon Supreme Court rejected the argument, noting that the defendant “asks for more than the reasonable suspicion standard requires.” Lichty, 835 P.2d at 907 . 2017The Oregon Supreme Court rejected the argument, noting that the defendant “asks for more than the reasonable suspicion standard requires.” Lichty, 835 P.2d at 907 . | 2 | 2017–2017 |
People v. Close
green
2 sentences2014These facts must justify more than a mere inarticulate hunch, "but need not rise to the level of suspicion required for probable cause." (Emphasis added.) Close, 238 Ill. 2d at 505 . ¶ 20 Here, the record reveals that the trial court erroneously applied the probable cause standard, rather than the reasonable suspicion standard, when it determined that the investigatory stop of defendant was improper. 2014These facts must justify more than a mere inarticulate hunch, “but need not rise to the level of suspicion required for probable cause.” (Emphasis added.) Close, 238 Ill. 2d at 505 . -6- ¶ 20 Here, the record reveals that the trial court erroneously applied the probable cause standard, rather than the reasonable suspicion standard, when it determined that the investigatory stop of defendant was improper. | 2 | 2014–2014 |
Maryland v. Buie
green
2 sentences2008Reasonable suspicion exists when “ ‘articulable facts which, taken together with the rational inferences from those facts, *** warrant a reasonably prudent officer’ to investigate further.” Lampitok, 207 Ill. 2d at 255 , quoting Maryland v. Buie, 494 U.S. 325, 334 , 108 L. 2008Reasonable suspicion exists when “ ‘articulable facts which, taken together with the rational inferences from those facts, *** warrant a reasonably prudent officer’ to investigate further.” Lampitok, 207 Ill. 2d at 255 , quoting Maryland v. Buie, 494 U.S. 325, 334 , 108 L. | 2 | 2008–2008 |
Griffin v. Wisconsin
green
2 sentences2007In fact, “reasonable suspicion” was held sufficient both under “special needs” analysis (Griffin, 483 U.S. at 875-76 , 97 L. 2007In fact, “reasonable suspicion” was held sufficient both under “special needs” analysis (Griffin, 483 U.S. at 875-76 , 97 L. | 2 | 2007–2007 |
Vernonia School District 47J v. Acton
green
2 sentences2005Ed. 2d 564 , 115 S. Ct. 2386 (1995), the United States Supreme Court loosened the reasonable suspicion requirement for school officials under the fourth amendment. 2005Ed. 2d 564 , 115 S. Ct. 2386 (1995), the United States Supreme Court loosened the reasonable suspicion requirement for school officials under the fourth amendment. | 2 | 2005–2005 |
In re Rafeal E.
green
1 sentence2023The defendant first discusses In re Rafeal E., 2014 IL App (1st) 133027 . | 1 | 2023–2023 |
| People v. Yanez neutral | 1 | 2020–2020 |
| People v. Maxey neutral | 1 | 2018–2018 |
| People v. Magallanes green | 1 | 2018–2018 |
| People v. Smith green | 1 | 2017–2017 |
| People v. Topor green | 1 | 2017–2017 |
| Pooler v. Motor Vehicles Division green | 1 | 2016–2016 |
| State v. Bryson green | 1 | 2016–2016 |
| People v. Sanders green | 1 | 2013–2013 |
| People v. Jackson green | 1 | 2009–2009 |
| People v. Parker green | 1 | 2005–2005 |
| M. Ex Rel. R. v. Board of Education Ball-Chatham Community Unit School District No. 5 green | 1 | 1996–1996 |
| People v. Alexander B. green | 1 | 1996–1996 |
| In Interest of SF green | 1 | 1996–1996 |
| MJ v. State green | 1 | 1996–1996 |
| State v. Young green | 1 | 1996–1996 |
| Cason v. Cook green | 1 | 1996–1996 |
| Wilcher v. State green | 1 | 1996–1996 |
| Martens Ex Rel. Martens v. District No. 220, Board of Education green | 1 | 1996–1996 |
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.