benchmark for judging any claim in Illinois

44 Illinois opinions name it 2 courts 1984–2026 15 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 (12)

Case	Followed	Cited
Strickland v. Washingtongreen scotus · 1984 · cited in 44 Illinois opinions naming this issue, 1984–2026 2 sentences 2026“The benchmark for judging any claim of ineffectiveness must be whether counsel’s conduct so undermined the proper functioning of the adversarial process that the trial cannot be relied on as having produced a just result.” Strickland v. Washington, 466 U.S. 668, 686 (1984). “[T]he proper standard for attorney performance is that of reasonably effective assistance.” Id. at 687 . 2026“The benchmark for judging any claim of ineffectiveness must be whether counsel’s conduct so undermined the proper functioning of the adversarial process that the trial cannot be relied on as having produced a just result.” Strickland v. Washington, 466 U.S. 668, 686 (1984). “[T]he proper standard for attorney performance is that of reasonably effective assistance.” Id. at 687 .	12	44
People v. Albanesegreen ill · 1984 · cited in 13 Illinois opinions naming this issue, 1991–2020 2 sentences 2020People v. Cloutier, 178 Ill. 2d 141, 163 (1997). “ ‘The benchmark for judging any claim of ineffectiveness must be whether counsel’s conduct so undermined the proper functioning of the adversarial process that the trial cannot be relied on as having produced a just result.’ ” People v. Albanese, 104 Ill. 2d 504, 525 (1984) (quoting Strickland, 466 U.S. at 686 ). 2016People v. Ramsey, 239 Ill. 2d 342, 433 (2010) (citing Strickland v. Washington, 466 U.S. 668, 687-88 (1984)). " 'The benchmark for judging any claim of ineffectiveness must be whether counsel's conduct so undermined the proper functioning of the adversarial process that the trial cannot be relied on as having produced a just result.' " People v. Albanese, 104 Ill. 2d 504, 525-26 (1984) (quoting Strickland, 466 U.S. at 686 ). ¶ 18 Taylor's argument is premised on his belief that Illinois law allows a defendant who is acting in imperfect self-defense to escape responsibility for attempted first	7	13
People v. Cloutiergreen ill · 1997 · cited in 2 Illinois opinions naming this issue, 2004–2020 2 sentences 2020People v. Cloutier, 178 Ill. 2d 141, 163 (1997). “ ‘The benchmark for judging any claim of ineffectiveness must be whether counsel’s conduct so undermined the proper functioning of the adversarial process that the trial cannot be relied on as having produced a just result.’ ” People v. Albanese, 104 Ill. 2d 504, 525 (1984) (quoting Strickland, 466 U.S. at 686 ). 2004People v. Cloutier, 178 Ill. 2d 141, 163 , 687 N.E.2d 930, 940 (1997). “ ‘The benchmark for judging any claim of ineffectiveness must be whether counsel’s conduct so undermined the proper functioning of the adversarial process that the trial cannot be relied on as having produced a just result.’ ” People v. Albanese, 104 Ill. 2d 504, 525 , 473 N.E.2d 1246, 1255 (1984), quoting Strickland, 466 U.S. at 686 , 80 L.	2	2
People v. Ramseygreen ill · 2010 · cited in 2 Illinois opinions naming this issue, 2016–2016 2 sentences 2016People v. Ramsey, 239 Ill. 2d 342, 433 (2010) (citing Strickland v. Washington, 466 U.S. 668, 687-88 (1984)). " 'The benchmark for judging any claim of ineffectiveness must be whether counsel's conduct so undermined the proper functioning of the adversarial process that the trial cannot be relied on as having produced a just result.' " People v. Albanese, 104 Ill. 2d 504, 525-26 (1984) (quoting Strickland, 466 U.S. at 686 ). ¶ 18 Taylor's argument is premised on his belief that Illinois law allows a defendant who is acting in imperfect self-defense to escape responsibility for attempted first 2016People v. Ramsey, 239 Ill. 2d 342, 433 (2010) (citing Strickland v. Washington, 466 U.S. 668, 687-88 (1984)). “ ‘The benchmark for judging any claim of ineffectiveness must be whether counsel’s conduct so undermined the proper functioning of the adversarial process that the trial cannot be relied on as having produced a just result.’ ” People v. Albanese, 104 Ill. 2d 504, 525-26 (1984) (quoting Strickland, 466 U.S. at 686 ). ¶ 18 Taylor’s argument is premised on his belief that Illinois law allows a defendant who is acting in imperfect self-defense to escape responsibility for attempted first	2	2
United States v. Mable Lindsaygreen ca7 · 1998 · cited in 2 Illinois opinions naming this issue, 2012–2012 2 sentences 2012Given the sketchy record on the ineffectiveness claim, perhaps the principle most important here is that a "strong presumption" exists that "trial counsel had good reasons for strategic decisions." United States v. Lindsay, 157 F.3d 532, 535 (7th Cir.1998). ¶ 47 I divide my analysis of trial counsel's performance into two sections. 2012Given the sketchy record on the ineffectiveness claim, perhaps the principle most important here is that a “strong presumption” exists that “trial counsel had good reasons for strategic decisions.” United States v. Lindsey, 157 F.3d 532, 535 (7th Cir. 1998). ¶ 47 I divide my analysis of trial counsel’s performance into two sections.	2	2
People v. Jacksongreen ill · 2001 · cited in 2 Illinois opinions naming this issue, 2008–2008 2 sentences 2008Ed. 2d 674, 691-92 , 104 S. Ct. 2052, 2063 (1984); People v. Jackson, 205 Ill. 2d 247, 258-59 (2001). “ ‘The benchmark for judging any claim of ineffectiveness must be whether counsel’s conduct so undermined the proper functioning of the adversarial process that the trial cannot be relied on as having produced a just result.’ ” People v. Albanese, 104 Ill. 2d 504, 525 , 473 N.E.2d 1246, 1255 (1984), quoting Strickland, 466 U.S. at 686 , 80 L. 2008Ed. 2d 674, 691-92 , 104 S. Ct. 2052, 2063 (1984); People v. Jackson, 205 Ill. 2d 247, 258-59 (2001). “ ‘The benchmark for judging any claim of ineffectiveness must be whether counsel’s conduct so undermined the proper functioning of the adversarial process that the trial cannot be relied on as having produced a just result.’ ” People v. Albanese, 104 Ill. 2d 504, 525 , 473 N.E.2d 1246, 1255 (1984), quoting Strickland, 466 U.S. at 686 , 80 L.	2	2
People v. Richardsongreen ill · 2000 · cited in 2 Illinois opinions naming this issue, 2012–2012 2 sentences 2012"The benchmark for judging any claim of ineffectiveness must be whether counsel's conduct so undermined the proper functioning of the adversarial process that the trial cannot be relied on as having produced a just result." Strickland, 466 U.S. at 686 , 104 S.Ct. 2052 . "[T]he defendant must prove that counsel made errors so serious, and that counsel's performance was so deficient, that counsel was not functioning as the `counsel' guaranteed by the sixth amendment." People v. Richardson, 189 Ill.2d 401, 411 , 245 Ill.Dec. 109 , 727 N.E.2d 362 (2000). "[C]ounsel's strategic decisions are virtua 2012"The benchmark for judging any claim of ineffectiveness must be whether counsel's conduct so undermined the proper functioning of the adversarial process that the trial cannot be relied on as having produced a just result." Strickland, 466 U.S. at 686 , 104 S.Ct. 2052 . "[T]he defendant must prove that counsel made errors so serious, and that counsel's performance was so deficient, that counsel was not functioning as the `counsel' guaranteed by the sixth amendment." People v. Richardson, 189 Ill.2d 401, 411 , 245 Ill.Dec. 109 , 727 N.E.2d 362 (2000). "[C]ounsel's strategic decisions are virtua	1	2
People v. Palmergreen ill · 1994 · cited in 2 Illinois opinions naming this issue, 2012–2012 2 sentences 2012"The benchmark for judging any claim of ineffectiveness must be whether counsel's conduct so undermined the proper functioning of the adversarial process that the trial cannot be relied on as having produced a just result." Strickland, 466 U.S. at 686 , 104 S.Ct. 2052 . "[T]he defendant must prove that counsel made errors so serious, and that counsel's performance was so deficient, that counsel was not functioning as the `counsel' guaranteed by the sixth amendment." People v. Richardson, 189 Ill.2d 401, 411 , 245 Ill.Dec. 109 , 727 N.E.2d 362 (2000). "[C]ounsel's strategic decisions are virtua 2012"The benchmark for judging any claim of ineffectiveness must be whether counsel's conduct so undermined the proper functioning of the adversarial process that the trial cannot be relied on as having produced a just result." Strickland, 466 U.S. at 686 , 104 S.Ct. 2052 . "[T]he defendant must prove that counsel made errors so serious, and that counsel's performance was so deficient, that counsel was not functioning as the `counsel' guaranteed by the sixth amendment." People v. Richardson, 189 Ill.2d 401, 411 , 245 Ill.Dec. 109 , 727 N.E.2d 362 (2000). "[C]ounsel's strategic decisions are virtua	1	2
People v. Pattersongreen ill · 2005 · cited in 2 Illinois opinions naming this issue, 2012–2012 2 sentences 2012"The benchmark for judging any claim of ineffectiveness must be whether counsel's conduct so undermined the proper functioning of the adversarial process that the trial cannot be relied on as having produced a just result." Strickland, 466 U.S. at 686 , 104 S.Ct. 2052 . "[T]he defendant must prove that counsel made errors so serious, and that counsel's performance was so deficient, that counsel was not functioning as the `counsel' guaranteed by the sixth amendment." People v. Richardson, 189 Ill.2d 401, 411 , 245 Ill.Dec. 109 , 727 N.E.2d 362 (2000). "[C]ounsel's strategic decisions are virtua 2012"The benchmark for judging any claim of ineffectiveness must be whether counsel's conduct so undermined the proper functioning of the adversarial process that the trial cannot be relied on as having produced a just result." Strickland, 466 U.S. at 686 , 104 S.Ct. 2052 . "[T]he defendant must prove that counsel made errors so serious, and that counsel's performance was so deficient, that counsel was not functioning as the `counsel' guaranteed by the sixth amendment." People v. Richardson, 189 Ill.2d 401, 411 , 245 Ill.Dec. 109 , 727 N.E.2d 362 (2000). "[C]ounsel's strategic decisions are virtua	1	2
People v. Harrisgreen ill · 1988 · cited in 1 Illinois opinions naming this issue, 1991–1991 2 sentences 1991Strickland directed that "the performance inquiry must be whether counsel's assistance was reasonable considering all the circumstances." ( Strickland, 466 U.S. at 688 , 104 S.Ct. at 2065 , 80 L.Ed.2d at 694 ; Albanese, 104 Ill.2d at 525 , 85 Ill.Dec. 441 , 473 N.E.2d 1246 ; see People v. Harris (1988), 123 Ill.2d 113, 156 , 122 Ill.Dec. 76 , 526 N.E.2d 335 .) A defendant must also overcome a strong presumption that the challenged action "might be considered sound trial strategy." ( Strickland, 466 U.S. at 689 , 104 S.Ct. at 2065 , 80 L.Ed.2d at 694-95 ; Albanese, 104 Ill.2d at 526 , 85 Ill.De 1991Strickland directed that "the performance inquiry must be whether counsel's assistance was reasonable considering all the circumstances." ( Strickland, 466 U.S. at 688 , 104 S.Ct. at 2065 , 80 L.Ed.2d at 694 ; Albanese, 104 Ill.2d at 525 , 85 Ill.Dec. 441 , 473 N.E.2d 1246 ; see People v. Harris (1988), 123 Ill.2d 113, 156 , 122 Ill.Dec. 76 , 526 N.E.2d 335 .) A defendant must also overcome a strong presumption that the challenged action "might be considered sound trial strategy." ( Strickland, 466 U.S. at 689 , 104 S.Ct. at 2065 , 80 L.Ed.2d at 694-95 ; Albanese, 104 Ill.2d at 526 , 85 Ill.De	1	1
People v. Johnsongreen ill · 1989 · cited in 1 Illinois opinions naming this issue, 1991–1991 2 sentences 1991See People v. Johnson (1989), 128 Ill. 2d 253, 265-66 , 538 N.E.2d 1118, 1123 ; People v. Caballero (1989), 126 Ill. 2d 248, 260 , 533 N.E.2d 1089, 1091 ; People v. Albanese (1984), 104 Ill. 2d 504, 524-25 , 473 N.E.2d 1246, 1255 (adopting Strickland in Illinois).) “ ‘The benchmark for judging any claim of ineffectiveness must be whether counsel’s conduct so undermined the proper functioning of the adversarial process that the trial cannot be relied on as having produced a just result.’ ” People v. Albanese, 104 Ill. 2d at 525 , quoting Strickland, 466 U.S. at 686 , 80 L. 1991See People v. Johnson (1989), 128 Ill. 2d 253, 265-66 , 538 N.E.2d 1118, 1123 ; People v. Caballero (1989), 126 Ill. 2d 248, 260 , 533 N.E.2d 1089, 1091 ; People v. Albanese (1984), 104 Ill. 2d 504, 524-25 , 473 N.E.2d 1246, 1255 (adopting Strickland in Illinois).) “ ‘The benchmark for judging any claim of ineffectiveness must be whether counsel’s conduct so undermined the proper functioning of the adversarial process that the trial cannot be relied on as having produced a just result.’ ” People v. Albanese, 104 Ill. 2d at 525 , quoting Strickland, 466 U.S. at 686 , 80 L.	1	1
McMann v. Richardsongreen scotus · 1970 · cited in 1 Illinois opinions naming this issue, 1984–1984 2 sentences 1984Ed. 2d 763 , 773 n.14, 90 S. Ct. 1441 , 1449 n.14.) “The benchmark for judging any claim of ineffectiveness must be whether counsel’s conduct so undermined the proper functioning of the adversarial process that the trial cannot be relied on as having produced a just result.” (Strickland v. Washington (1984), 466 U.S. _ , _, 80 L. 1984The Supreme Court has also recognized that the mere presence of counsel at trial is not enough. "[T]he right to counsel is the right to the effective assistance of counsel." ( McMann v. Richardson (1970), 397 U.S. 759, 771, n. 14 , 25 L.Ed.2d 763 , 773 n. 14, 90 S.Ct. 1441 , 1449 n. 14.) "The benchmark for judging any claim of ineffectiveness must be whether counsel's conduct so undermined the proper functioning of the adversarial process that the trial cannot be relied on as having produced a just result." ( Strickland *256 v. Washington (1984), 466 U.S. ___ , ___, 80 L.Ed.2d 674, 692-93 , 10	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 (6)

Case	Cited	Years
People v. Yankaway green ill · 2025 2 sentences 2026The failure to satisfy either prong of the Strickland test precludes a finding of ineffective assistance of [trial] counsel.” People v. Yankaway, 2025 IL 130207, ¶ 62 . ¶ 87 “The benchmark for judging any claim of ineffectiveness must be whether [trial] counsel’s conduct so undermined the proper functioning of the adversarial process that the trial cannot be 34 relied on as having produced a just result.” Strickland, 466 U.S. at 686 . 2026“To prevail, the defendant must satisfy both prongs of the Strickland test. [Citation.] The failure to satisfy either prong of the Strickland test precludes a finding of ineffective assistance of [trial] counsel.” People v. Yankaway, 2025 IL 130207, ¶ 62 . ¶ 28 “The benchmark for judging any claim of ineffectiveness must be whether [trial] counsel’s conduct so undermined the proper functioning of the adversarial process that the trial cannot be relied on as having produced a just result.” Strickland, 466 U.S. at 686 .	2	2026–2026
Matter of Carmody green illappct · 1995 2 sentences 2014In judging counsel's effectiveness in an involuntary-commitment proceeding, courts focus "upon whether the respondent's counsel acted so as to hold the State to its burden of proof and its procedural requirements." Carmody, 274 Ill. 2014In judging counsel’s effectiveness in an involuntary-commitment proceeding, courts focus “upon whether the respondent’s counsel acted so as to hold the State to its burden of proof and its procedural requirements.” Carmody, 274 Ill.	2	2014–2014
People v. Elam green illappct · 1987 2 sentences 1987App. 3d 685 , 509 N.E.2d 698 .) The benchmark for judging any claim of ineffectiveness must be whether counsel’s conduct “so undermined the proper functioning of the adversarial process that the trial cannot be relied on as having produced a just result.” Strickland v. Washington (1984), 466 U.S. 668, 686 , 80 L. 1987App. 3d 685 , 509 N.E.2d 698 .) The benchmark for judging any claim of ineffectiveness must be whether counsel’s conduct “so undermined the proper functioning of the adversarial process that the trial cannot be relied on as having produced a just result.” Strickland, 466 U.S. at 686 , 80 L.	2	1987–1987
People v. Wright green ill · 1986 2 sentences 1995Ed. 2d 674, 693 , 104 S. Ct. 2052, 2064 ; People v. Wright (1986), 111 Ill. 2d 18, 30 , 488 N.E.2d 973, 979 .) The benchmark for judging any claim of ineffectiveness must be whether counsel’s conduct so undermined the proper functioning of the adversarial process that the trial cannot be relied on as having produced a just result. 1995Ed. 2d 674, 693 , 104 S. Ct. 2052, 2064 ; People v. Wright (1986), 111 Ill. 2d 18, 30 , 488 N.E.2d 973, 979 .) The benchmark for judging any claim of ineffectiveness must be whether counsel’s conduct so undermined the proper functioning of the adversarial process that the trial cannot be relied on as having produced a just result.	1	1995–1995
People v. Caballero green ill · 1989 2 sentences 1991See People v. Johnson (1989), 128 Ill. 2d 253, 265-66 , 538 N.E.2d 1118, 1123 ; People v. Caballero (1989), 126 Ill. 2d 248, 260 , 533 N.E.2d 1089, 1091 ; People v. Albanese (1984), 104 Ill. 2d 504, 524-25 , 473 N.E.2d 1246, 1255 (adopting Strickland in Illinois).) “ ‘The benchmark for judging any claim of ineffectiveness must be whether counsel’s conduct so undermined the proper functioning of the adversarial process that the trial cannot be relied on as having produced a just result.’ ” People v. Albanese, 104 Ill. 2d at 525 , quoting Strickland, 466 U.S. at 686 , 80 L. 1991See People v. Johnson (1989), 128 Ill. 2d 253, 265-66 , 538 N.E.2d 1118, 1123 ; People v. Caballero (1989), 126 Ill. 2d 248, 260 , 533 N.E.2d 1089, 1091 ; People v. Albanese (1984), 104 Ill. 2d 504, 524-25 , 473 N.E.2d 1246, 1255 (adopting Strickland in Illinois).) “ ‘The benchmark for judging any claim of ineffectiveness must be whether counsel’s conduct so undermined the proper functioning of the adversarial process that the trial cannot be relied on as having produced a just result.’ ” People v. Albanese, 104 Ill. 2d at 525 , quoting Strickland, 466 U.S. at 686 , 80 L.	1	1991–1991
United States v. Cronic green scotus · 1984 2 sentences 1989To prevail, a 309 defendant must show: (1) counsel's representation fell below an objective standard of reasonableness; and (2) that deficiencies prejudiced the defendant thereby depriving him of a fair trial, and but for such deficiencies the result of the proceedings would have been different. ( Strickland, 466 U.S. at 687 , 80 L.Ed.2d at 693 , 104 S.Ct. at 2064 .) "The benchmark for judging any claim of ineffectiveness must be whether counsel's conduct so undermined the proper functioning of the adversarial process that the trial cannot be relied on as having produced a just result." Stric 1989To prevail, a 309 defendant must show: (1) counsel's representation fell below an objective standard of reasonableness; and (2) that deficiencies prejudiced the defendant thereby depriving him of a fair trial, and but for such deficiencies the result of the proceedings would have been different. ( Strickland, 466 U.S. at 687 , 80 L.Ed.2d at 693 , 104 S.Ct. at 2064 .) "The benchmark for judging any claim of ineffectiveness must be whether counsel's conduct so undermined the proper functioning of the adversarial process that the trial cannot be relied on as having produced a just result." Stric	1	1989–1989

Statutes the citing opinions construe

IL § 720 ILCS 5/9-1 (7) IL § 720 ILCS 5/7-1 (4) IL § 720 ILCS 5/8-4 (4) IL § 720 ILCS 5/9-2 (3) IL § 725 ILCS 5/122-1 (3) IL § 725 ILCS 5/122-2.1 (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.

Where else courts name it

MS 191 (1990–2025) OH 119 (1986–2025) TX 84 (1986–2025) WY 56 (1986–2024) TN 49 (1994–2021) IN 46 (1984–2025) IL 44 (1984–2026) IA 26 (1985–2026) MO 20 (1985–2023) CA 18 (1992–2021) PA 15 (1995–2020) CT 13 (1985–2022) MD 13 (1985–2026) UT 12 (1993–2019) GA 11 (1986–2015) DC 11 (1984–2012) WI 11 (1985–2025) KS 11 (1985–2024) DE 8 (2019–2026) FL 8 (1990–2018) VA 8 (1986–2004) ID 8 (1985–2010) WA 7 (1984–2023) SD 7 (1987–2018) RI 7 (1993–2011) OK 7 (1986–2009) AR 6 (2003–2021) LA 6 (1993–2024) MN 5 (1985–2019) NJ 5 (1989–2008) CO 5 (2003–2015) NM 4 (1985–2009) AL 4 (1985–1992) MI 4 (2022–2025) NC 4 (1985–2018) NE 3 (1986–2023) KY 3 (2008–2022) OR 3 (2005–2022) AZ 2 (1984–1986)

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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