Sprinkle doctrine in Illinois

47 Illinois opinions name it 2 courts 2009–2025 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 (10)

Case	Followed	Cited
People v. Thompsongreen ill · 2010 · cited in 20 Illinois opinions naming this issue, 2010–2024 2 sentences 2024Under the Sprinkle doctrine, the forfeiture rule may be relaxed when a trial judge oversteps its authority in the jury’s presence or when counsel has been effectively prevented from objecting because it would have “fallen on deaf ears.” Thompson, 238 Ill. 2d at 613 ; see People v. McLaurin, 235 Ill. 2d 478, 488 (2009) (same). 2024Under the Sprinkle doctrine, the forfeiture rule may be relaxed when a trial judge oversteps its authority in the jury’s presence or when counsel has been effectively prevented from objecting because it would have “fallen on deaf ears.” Thompson, 238 Ill. 2d at 613 ; see People v. McLaurin, 235 Ill. 2d 478, 488 (2009) (same).	15	20
The People v. Sprinklegreen ill · 1963 · cited in 16 Illinois opinions naming this issue, 2009–2023 2 sentences 2023However, he contends his forfeiture should be overlooked because (1) the forfeiture rule is applied less rigidly when “the basis for the objection is the judge’s conduct” or (2) plain error occurred. ¶ 37 In People v. Sprinkle, 27 Ill. 2d 398, 401 , 189 N.E.2d 295, 297 (1963), the supreme court “first recognized that judicial misconduct could provide a basis for relaxing the forfeiture rule.” People v. McLaurin, 235 Ill. 2d 478, 485 , 922 N.E.2d 344, 349 (2009). “[U]under the Sprinkle doctrine, the forfeiture rule may be relaxed when a trial judge oversteps his or her authority in the presence 2023This principle is commonly referred to as the “Sprinkle doctrine,” as it arises from People v. Sprinkle, 27 Ill. 2d 398, 401 (1963).	14	16
People v. McLauringreen ill · 2009 · cited in 18 Illinois opinions naming this issue, 2009–2025 2 sentences 2025However, the Sprinkle doctrine is only applicable where trial counsel’s objection would have “fallen on deaf ears.” See People v. McLaurin, 235 Ill. 2d 478, 489 (2009). 2025However, the Sprinkle doctrine is only applicable where trial counsel’s objection would have “fallen on deaf ears.” See People v. McLaurin, 235 Ill. 2d 478, 489 (2009).	11	18
People v. Hansongreen ill · 2010 · cited in 9 Illinois opinions naming this issue, 2010–2017 2 sentences 2017This concept is known as the Sprinkle doctrine, as it arises from People v. Sprinkle, 27 Ill. 2d 398, 401 (1963), in which our supreme court held that less rigid application of the forfeiture rule “should prevail where the basis for the objection is the conduct of the trial judge.” In the context of a bench trial, this less rigid forfeiture rule should be applied “when counsel has been effectively prevented from objecting because it would have ‘ “fallen on deaf ears.” ’ ” People v. Thompson, 238 Ill. 2d 598, 612 (2010) (quoting People v. Hanson, 238 Ill. 2d 74, 118 (2010), quoting People v. Mc 2017This concept is known as the Sprinkle doctrine, as it arises from People v. Sprinkle, 27 Ill. 2d 398, 401 (1963), in which our supreme court held that less rigid application of the forfeiture rule “should prevail where the basis for the objection is the conduct of the trial judge.” In the context of a bench trial, this less rigid forfeiture rule should be applied “when counsel has been effectively prevented from objecting because it would have ‘ “fallen on deaf ears.” ’ ” People v. Thompson, 238 Ill. 2d 598, 612 (2010) (quoting People v. Hanson, 238 Ill. 2d 74, 118 (2010), quoting People v. Mc	9	9
People v. Davisgreen illappct · 2007 · cited in 4 Illinois opinions naming this issue, 2012–2022 2 sentences 2022Alternatively, defendant requests that we review the issue for plain error. ¶ 14 The Sprinkle doctrine allows a reviewing court to relax forfeiture rules where counsel has been effectively prevented from objecting because it “ ‘would have fallen on deaf ears.’ ” People 5 v. McLaurin, 235 Ill. 2d 478, 488 (2009) (quoting People v. Davis, 378 Ill. 2022Alternatively, defendant requests that we review the issue for plain error. ¶ 14 The Sprinkle doctrine allows a reviewing court to relax forfeiture rules where counsel has been effectively prevented from objecting because it “ ‘would have fallen on deaf ears.’ ” People 5 v. McLaurin, 235 Ill. 2d 478, 488 (2009) (quoting People v. Davis, 378 Ill.	3	4
People v. Damerongreen ill · 2001 · cited in 3 Illinois opinions naming this issue, 2009–2010 2 sentences 2010McLaurin, 235 Ill.2d at 488 , 337 Ill.Dec. 221 , 922 N.E.2d 344 , citing People v. Woolley, 205 Ill.2d 296, 301-02 , 275 Ill. 413 Dec. 748, 793 N.E.2d 519 (2002); People v. Dameron, 196 Ill.2d 156, 171 , 256 Ill.Dec. 274 , 751 N.E.2d 1111 (2001). 2010McLaurin, 235 Ill.2d at 488 , 337 Ill.Dec. 221 , 922 N.E.2d 344 , citing People v. Woolley, 205 Ill.2d 296, 301-02 , 275 Ill. 413 Dec. 748, 793 N.E.2d 519 (2002); People v. Dameron, 196 Ill.2d 156, 171 , 256 Ill.Dec. 274 , 751 N.E.2d 1111 (2001).	3	3
People v. Nevittgreen ill · 1990 · cited in 3 Illinois opinions naming this issue, 2010–2014 2 sentences 2014Nevertheless, defendant, citing People v. Nevitt, 135 Ill. 2d 423 (1990), asserts the issue involves the conduct of the trial court and should not be considered forfeited. ¶ 23 Although judicial misconduct may provide a basis for relaxing the forfeiture rule under the Sprinkle doctrine (People v. Hanson, 238 Ill. 2d 74, 117 (2010)), our supreme court has made clear this exception applies only in extraordinary situations, such as when a judge makes inappropriate comments to the jury or relies on social commentary in sentencing defendant to -6- death. 2014Nevertheless, defendant, citing People v. Nevitt, 135 Ill. 2d 423 (1990), asserts the issue involves the conduct of the trial court and should not be considered forfeited. ¶ 23 Although judicial misconduct may provide a basis for relaxing the forfeiture rule under the Sprinkle doctrine (People v. Hanson, 238 Ill. 2d 74, 117 (2010)), our supreme court has made clear this exception applies only in extraordinary situations, such as when a judge makes inappropriate comments to the jury or relies on social commentary in sentencing defendant to -6- death.	2	3
People v. Woolleygreen ill · 2002 · cited in 3 Illinois opinions naming this issue, 2009–2010 2 sentences 2009Like the plain-error doctrine, the Sprinkle principle is primarily concerned with ensuring a fair trial. 1 Woolley, 205 Ill. 2d at 301 , citing Sprinkle, 27 Ill. 2d at 400 . 2009Like the plain-error doctrine, the Sprinkle principle is primarily concerned with ensuring a fair trial. [1] Woolley, 205 Ill.2d at 301 , 275 Ill.Dec. 748 , 793 N.E.2d 519 , citing Sprinkle, 27 Ill.2d at 400 , 189 N.E.2d 295 .	2	3
People v. Williamsgreen ill · 1996 · cited in 1 Illinois opinions naming this issue, 2009–2009 2 sentences 2009See People v. Dameron, 196 Ill. 2d 156, 171 (2001) (reviewing trial judge’s reliance, in sentencing defendant to death, on a book that was not in evidence); People v. Davis, 185 Ill. 2d 317, 344 (1998) (reviewing trial judge’s alleged refusal to consider mitigating evidence in capital sentencing hearing); People v. Williams, 173 Ill. 2d 48, 85 (1996) (reviewing trial judge’s alleged refusal to allow defense counsel to participate in formulating responses to jury notes). 2009See People v. Dameron, 196 Ill.2d 156, 171 , 256 Ill.Dec. 274 , 751 N.E.2d 1111 (2001) (reviewing trial judge's reliance, in sentencing defendant to death, on a book that was not in evidence); People v. Davis, 185 Ill.2d 317, 344 , 235 Ill.Dec. 918 , 706 N.E.2d 473 (1998) (reviewing trial judge's alleged refusal to consider mitigating evidence in capital sentencing hearing); People v. Williams, 173 Ill.2d 48, 85 , 218 Ill.Dec. 916 , 670 N.E.2d 638 (1996) (reviewing trial judge's alleged refusal to allow defense counsel to participate in formulating responses to jury notes).	1	1
People v. Davisgreen ill · 1998 · cited in 1 Illinois opinions naming this issue, 2009–2009 2 sentences 2009See People v. Dameron, 196 Ill. 2d 156, 171 (2001) (reviewing trial judge’s reliance, in sentencing defendant to death, on a book that was not in evidence); People v. Davis, 185 Ill. 2d 317, 344 (1998) (reviewing trial judge’s alleged refusal to consider mitigating evidence in capital sentencing hearing); People v. Williams, 173 Ill. 2d 48, 85 (1996) (reviewing trial judge’s alleged refusal to allow defense counsel to participate in formulating responses to jury notes). 2009See People v. Dameron, 196 Ill.2d 156, 171 , 256 Ill.Dec. 274 , 751 N.E.2d 1111 (2001) (reviewing trial judge's reliance, in sentencing defendant to death, on a book that was not in evidence); People v. Davis, 185 Ill.2d 317, 344 , 235 Ill.Dec. 918 , 706 N.E.2d 473 (1998) (reviewing trial judge's alleged refusal to consider mitigating evidence in capital sentencing hearing); People v. Williams, 173 Ill.2d 48, 85 , 218 Ill.Dec. 916 , 670 N.E.2d 638 (1996) (reviewing trial judge's alleged refusal to allow defense counsel to participate in formulating responses to jury notes).	1	1

Distinguished, questioned or overruled (0)

Case	Negative	Cited
No negative-treatment citations attached to this issue in Illinois. Read the followed side critically anyway.

Also cited on this issue (4)

Case	Cited	Years
People v. Sims green ill · 2000 2 sentences 2009See People v. Sprinkle, 27 Ill. 2d 398 , 189 N.E.2d 295 (1963) (recognizing the practical difficulties of contemporaneous objections to a trial judge’s conduct); People v. Sims, 192 Ill. 2d 592 , 736 N.E.2d 1048 (2000) (same, relying on Sprinkle analysis). 2009See People v. Sprinkle, 27 Ill. 2d 398 , 189 N.E.2d 295 (1963) (recognizing the practical difficulties of contemporaneous objections to a trial judge’s conduct); People v. Sims, 192 Ill. 2d 592 , 736 N.E.2d 1048 (2000) (same, relying on Sprinkle analysis).	4	2009–2009
People v. James green illappct · 1993 2 sentences 2015Id. at 531 . ¶ 24 Under the Sprinkle doctrine, the forfeiture rule may also be relaxed in certain circumstances, such as "when a trial judge oversteps his or her authority in the presence of the jury or when counsel has effectively been prevented from objecting because it would have fallen on deaf ears." (Internal quotation marks omitted.) People v. Thompson, 238 Ill. 2d 598, 612 (2010) (quoting People v. Hanson, 238 Ill. 2d 74, 118 (2010)). 2015Id. at 531 . ¶ 24 Under the Sprinkle doctrine, the forfeiture rule may also be relaxed in certain circumstances, such as "when a trial judge oversteps his or her authority in the presence of the jury or when counsel has effectively been prevented from objecting because it would have fallen on deaf ears." (Internal quotation marks omitted.) People v. Thompson, 238 Ill. 2d 598, 612 (2010) (quoting People v. Hanson, 238 Ill. 2d 74, 118 (2010)).	3	2015–2015
People v. Hillier green ill · 2010 2 sentences 2020To obtain relief under the plain-error doctrine, “a defendant must first show that a clear or obvious error occurred.” Hillier, 237 Ill. 2d at 545 . 2020To obtain relief under the plain-error doctrine, “a defendant must first show that a clear or obvious error occurred.” Hillier, 237 Ill. 2d at 545 .	1	2020–2020
People v. McLaurin green illappct · 2008 2 sentences 2009Accordingly, a defendant who successfully invokes Sprinkle is not limited in the same ways as a defendant relying solely on plain-error review. [2] When it concluded that the trial court had violated defendant's "substantial constitutional rights protected by the federal and state constitutions," the appellate court did not specify which federal constitutional right had been denied defendant. 382 Ill.App.3d at 653 , 323 Ill.Dec. 579 , 894 N.E.2d 138 . 2009Accordingly, a defendant who successfully invokes Sprinkle is not limited in the same ways as a defendant relying solely on plain-error review. [2] When it concluded that the trial court had violated defendant's "substantial constitutional rights protected by the federal and state constitutions," the appellate court did not specify which federal constitutional right had been denied defendant. 382 Ill.App.3d at 653 , 323 Ill.Dec. 579 , 894 N.E.2d 138 .	1	2009–2009

Statutes the citing opinions construe

IL § 725 ILCS 5/115-10.1 (5) IL § 705 ILCS 405/5-130 (4) IL § 720 ILCS 5/24-1.1 (4) IL § 720 ILCS 5/24-1.6 (4) IL § 730 ILCS 5/5-4.5-30 (4) IL § 730 ILCS 5/5-8-4 (4) IL § 720 ILCS 5/11-1.20 (3) IL § 720 ILCS 5/12-14.1 (3) IL § 730 ILCS 5/5-8-1 (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.

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