expert standard (Illinois) · Go Syfert
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expert standard in Illinois

44 Illinois opinions name it 2 courts 1979–2025 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.

Followed or applied (12)

CaseFollowedCited
Dolan v. Galluzzogreen
ill · 1979 · cited in 21 Illinois opinions naming this issue, 1986–2025
2 sentences

2025Thus, the court concluded that “in order to testify as an expert on the standard of care in a given school of medicine, the witness must be licensed therein.” Id. at 285 .

2025Thus, the court concluded that “in order to testify as an expert on the standard of care in a given school of medicine, the witness must be licensed therein.” Id. at 285 .

421
Sullivan v. Edward Hospitalgreen
ill · 2004 · cited in 6 Illinois opinions naming this issue, 2004–2009
2 sentences

2007The special concurrence states: "The supreme court held in Sullivan that ' "in order to testify as an expert on the standard of care in a given school of medicine, the witness must be licensed therein." ' (Emphasis added.) Sullivan, 209 Ill. 2d at 114 , quoting Dolan, 77 Ill. 2d at 285. *** Sullivan can be read but one way: the testimony of a witness cannot be considered competent medical opinion testimony unless the witness holds a medical license at the time of the testimony." Slip op. at 21.

2007The special concurrence states: “The supreme court held in Sullivan that ‘ “in order to testify as an expert on the standard of care in a given school of medicine, the witness must be licensed therein.” ’ (Emphasis added.) Sullivan, 209 Ill. 2d at 114 , quoting Dolan, 77 Ill. 2d at 285. *** Sullivan can be read but one way: the testimony of a witness cannot be considered competent medical opinion testimony unless the witness holds a medical license at the time of the testimony.” 373 Ill.

46
Tsoukas v. Lapidgreen
illappct · 2000 · cited in 4 Illinois opinions naming this issue, 2011–2015
2 sentences

2015Taylor v. County of Cook, 2011 IL App (1st) 093085, ¶ 36 ("When multiple defendants are named in a case, each defendant is entitled to present an expert in defense of the case." (citing Tsoukas v. Lapid, 315 Ill.

2015Taylor v. County of Cook, 2011 IL App (1st) 093085, ¶ 36 (“When multiple defendants are named in a case, each defendant is entitled to present an expert in defense of the case.” (citing Tsoukas v. Lapid, 315 Ill.

34
Taylor v. County of Cookgreen
illappct · 2011 · cited in 4 Illinois opinions naming this issue, 2015–2017
2 sentences

2015Taylor v. County of Cook, 2011 IL App (1st) 093085, ¶ 36 ("When multiple defendants are named in a case, each defendant is entitled to present an expert in defense of the case." (citing Tsoukas v. Lapid, 315 Ill.

2015Taylor v. County of Cook, 2011 IL App (1st) 093085, ¶ 36 (“When multiple defendants are named in a case, each defendant is entitled to present an expert in defense of the case.” (citing Tsoukas v. Lapid, 315 Ill.

24
United States v. Robert Theodore Bassgreen
ca9 · 1973 · cited in 2 Illinois opinions naming this issue, 2017–2017
2 sentences

2017But the court adopted, as a guideline, the precept that the court should “ ‘authorize defense services when the defense attorney makes a timely request in 17 No. 1-14-2258 circumstances in which a reasonable attorney would engage such services for a client having the independent financial means to pay for them.’ ” Durant, 545 F.2d at 827 (quoting United States v. Bass, 477 F.2d 723, 725 (9th Cir. 1973)). ¶ 53 The Durant court held: “ ‘[A]n adequate defense’ must include preparation for cross-examination of a government expert as well as presentation of an expert defense witness.

2017But the court adopted, as a guideline, the precept that the court should “ ‘authorize defense services when the defense attorney makes a timely request in circumstances in which a reasonable attorney would engage such services for a client having the independent financial means to pay for them.’ ” Durant, 545 F.2d at 827 (quoting United States v. Bass, 477 F.2d 723, 725 (9th Cir. 1973)). ¶ 53 The Durant court held: “ ‘[A]n adequate defense’ must include preparation for cross-examination of a government expert as well as presentation of an expert defense witness.

22
Gill v. Fostergreen
ill · 1993 · cited in 2 Illinois opinions naming this issue, 2011–2011
2 sentences

2011Noting that a "practitioner of a particular school of medicine is entitled to have his conduct tested by the standards of his school," the supreme court held that "in order to testify as an expert on the standard of care in a given school of medicine, the witness must be licensed therein." Id. at 283, 285 , 32 Ill.Dec. 900 , 396 N.E.2d 13 ; see also Gill v. Foster, 157 Ill.2d 304 , 193 Ill.Dec. 157 , 626 N.E.2d 190 (1993) (reaffirming Dolan's holding); Jones v. O'Young, 154 Ill.2d 39 , 180 Ill.Dec. 330 , 607 N.E.2d 224 (1992) (same).

2011Noting that a "practitioner of a particular school of medicine is entitled to have his conduct tested by the standards of his school," the supreme court held that "in order to testify as an expert on the standard of care in a given school of medicine, the witness must be licensed therein." Id. at 283, 285 , 32 Ill.Dec. 900 , 396 N.E.2d 13 ; see also Gill v. Foster, 157 Ill.2d 304 , 193 Ill.Dec. 157 , 626 N.E.2d 190 (1993) (reaffirming Dolan's holding); Jones v. O'Young, 154 Ill.2d 39 , 180 Ill.Dec. 330 , 607 N.E.2d 224 (1992) (same).

22
Purtill v. Hessgreen
ill · 1986 · cited in 2 Illinois opinions naming this issue, 2007–2007
2 sentences

2007Once the fact of such license has been established, it lies within the sound discretion of the trial court to determine if the witness is qualified to testify as an expert regarding the standard of care. [Citation.]" The supreme court reaffirmed the common-law licensure requirement in Purtill v. Hess, 111 Ill. 2d 229, 243 (1986) ("It must be established that the expert is a licensed member of the school of medicine about which he proposes to express an opinion").

2007Once the fact of such license has been established, it lies within the sound discretion of the trial court to determine if the witness is qualified to testify as an expert regarding the standard of care. [Citation.]” The supreme court reaffirmed the common-law licensure requirement in Purtill v. Hess, 111 Ill. 2d 229, 243 (1986) (“It must be established that the expert is a licensed member of the school of medicine about which he proposes to express an opinion”).

22
People v. Graygreen
ill · 2017 · cited in 1 Illinois opinions naming this issue, 2021–2021
1 sentence

2021See Gray, 2017 IL 120958, ¶ 35 . ¶ 54 Similarly, although both the State’s expert and the defense’s expert opined that the shotgun could have accidentally discharged based on its age and modifications, the jury was not required to believe that the firearm did actually accidentally discharge in this case, but rather was merely required to listen to the testimony and determine its relative weight.

11
People v. Hillgreen
illappct · 1998 · cited in 1 Illinois opinions naming this issue, 2021–2021
1 sentence

2021See People v. Hill, 297 Ill.

11
People v. Milesgreen
illappct · 1991 · cited in 1 Illinois opinions naming this issue, 2014–2014
1 sentence

2014Greer-Ritzheimer explained that the frequency calculation was the mathematical product of the frequencies of the individual loci, i.e., that the frequency calculation was based upon the “product rule.” See People v. Miles, 217 Ill.

11
Lombardo v. Reliance Elevator Co.green
illappct · 2000 · cited in 1 Illinois opinions naming this issue, 2012–2012
1 sentence

2012See Lombardo, 315 Ill.

11
People v. Davenportgreen
illappct · 1998 · cited in 1 Illinois opinions naming this issue, 2001–2001
2 sentences

2001See People v. Davenport, 301 Ill.App.3d at 150 , 234 Ill.Dec. 169 , 702 N.E.2d 335 (holding that allowing Detective Bloore to testify as an expert was not error).

2001See People v. Davenport, 301 Ill.App.3d at 150 , 234 Ill.Dec. 169 , 702 N.E.2d 335 (holding that allowing Detective Bloore to testify as an expert was not error).

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 (14)

CaseCitedYears
Knight v. Haydary green
illappct · 1992
2 sentences

1997Knight v. Haydary, 223 Ill.

1997Knight v. Haydary, 223 Ill.

31992–1997
United States v. David Durant green
ca2 · 1976
2 sentences

2017But the court adopted, as a guideline, the precept that the court should “ ‘authorize defense services when the defense attorney makes a timely request in 17 No. 1-14-2258 circumstances in which a reasonable attorney would engage such services for a client having the independent financial means to pay for them.’ ” Durant, 545 F.2d at 827 (quoting United States v. Bass, 477 F.2d 723, 725 (9th Cir. 1973)). ¶ 53 The Durant court held: “ ‘[A]n adequate defense’ must include preparation for cross-examination of a government expert as well as presentation of an expert defense witness.

2017Following the reasoning of Durant, 545 F.2d at 827-29 , we find that we must reverse the 23 No. 1-14-2258 convictions and remand for a new trial because of the trial court’s constitutional error of denying Djurdjulov’s motion for the funds he needed to hire an expert to challenge Raschke’s testimony. ¶ 63 Because we vacate the convictions, we need not address Djurdjulov’s arguments about his sentences. ¶ 64 CONCLUSION ¶ 65 The State sufficiently showed that in 36 hours of detention starting on March 10, 2009, Djurdjulov voluntarily answered questions about his actions after midnight on January

22017–2017
Somers v. Quinn green
illappct · 2007
2 sentences

2012Somers, 373 Ill.

2007The special concurrence states: "The supreme court held in Sullivan that `"in order to testify as an expert on the standard of care in a given school of medicine, the witness must be licensed therein."' (Emphasis added.) Sullivan, 209 Ill.2d at 114 [ 282 Ill.Dec. 348 , 806 N.E.2d 645 ], quoting Dolan [ v. Galluzzo ], 77 Ill.2d [279] at 285 [ 32 Ill.Dec. 900 , 396 N.E.2d 13 (1979) ]. * * * Sullivan can be read but one way: the testimony of a witness cannot be considered competent medical opinion testimony unless the witness holds a medical license at the time of the testimony." Op. 310 Ill.Dec.

22007–2012
Jones v. O'YOUNG green
ill · 1992
2 sentences

2011Noting that a "practitioner of a particular school of medicine is entitled to have his conduct tested by the standards of his school," the supreme court held that "in order to testify as an expert on the standard of care in a given school of medicine, the witness must be licensed therein." Id. at 283, 285 , 32 Ill.Dec. 900 , 396 N.E.2d 13 ; see also Gill v. Foster, 157 Ill.2d 304 , 193 Ill.Dec. 157 , 626 N.E.2d 190 (1993) (reaffirming Dolan's holding); Jones v. O'Young, 154 Ill.2d 39 , 180 Ill.Dec. 330 , 607 N.E.2d 224 (1992) (same).

2011Noting that a "practitioner of a particular school of medicine is entitled to have his conduct tested by the standards of his school," the supreme court held that "in order to testify as an expert on the standard of care in a given school of medicine, the witness must be licensed therein." Id. at 283, 285 , 32 Ill.Dec. 900 , 396 N.E.2d 13 ; see also Gill v. Foster, 157 Ill.2d 304 , 193 Ill.Dec. 157 , 626 N.E.2d 190 (1993) (reaffirming Dolan's holding); Jones v. O'Young, 154 Ill.2d 39 , 180 Ill.Dec. 330 , 607 N.E.2d 224 (1992) (same).

22011–2011
Greenberg v. Michael Reese Hospital green
ill · 1980
2 sentences

2008The restriction as to who may serve as an expert applies to testimony “concerning the standard of care.” (Emphasis added.) Greenberg v. Michael Reese Hospital, 83 Ill. 2d 282, 291-92 , 415 N.E.2d 390 (1980), citing Dolan v. Galluzzo, 77 Ill. 2d 279, 283 , 396 N.E.2d 13 (1979).

2008The restriction as to who may serve as an expert applies to testimony “concerning the standard of care.” (Emphasis added.) Greenberg v. Michael Reese Hospital, 83 Ill. 2d 282, 291-92 , 415 N.E.2d 390 (1980), citing Dolan v. Galluzzo, 77 Ill. 2d 279, 283 , 396 N.E.2d 13 (1979).

22008–2008
Kosinski v. Inland Steel Co. green
illappct · 1989
2 sentences

1998Kosinski , 192 Ill.

1998Kosinski, 192 Ill.

21998–1998
In re Detention of New green
ill · 2014
1 sentence

2025Dr. Neu’s testimony was not “original or striking” scientific evidence that did not “resembl[e] something formerly known.” In re Detention of New, 2014 IL 116306, ¶ 34 .

12025–2025
People v. Coleman green
ill · 1998
1 sentence

2014Coleman, 183 Ill. 2d at 397 . ¶ 132 Defendant’s contention regarding his attorneys’ failure to hire an expert to challenge the frequency calculations is similarly unavailing.

12014–2014
State v. Dixon green
minnctapp · 2012
1 sentence

2013While of the opinion that “ACE-V is not accepted as an objective, scientifically validated protocol,” Dr. Zabell acknowledged that “it is viewed by many in the scientific community as a framework for subjective assessment with a limited amount of detail.” Id. at 670 .

12013–2013
Thompson v. Gordon green
ill · 2006
2 sentences

2012Thompson I, 221 Ill. 2d at 429 .

2012Thompson I, 221 Ill. 2d at 430 . ¶ 24 In Somers, the appellate court similarly held that the trial court erred in concluding that a witness who had lost his license to practice medicine was automatically barred from testifying as an expert to the standard of care for a physician.

12012–2012
BOATMEN'S NAT. BANK OF BELLEVILLE v. Martin green
illappct · 1992
1 sentence

1994App. 3d 740 , 585 N.E.2d 1328 , a treating physician was permitted to testify as an expert on the standard of care, although he was not previously disclosed as a Rule 220 expert.

11994–1994
Barth v. Reagan green
ill · 1990
1 sentence

1992(Barth, 139 Ill. 2d at 418 .) Rule 220 also allows a court to set its own cutoff dates for the disclosure and discovery of an expert and to bar an expert whose disclosure does not comply with the court-set deadlines.

11992–1992
Coffey v. Hancock green
illappct · 1984
1 sentence

1989App. 3d 442, 451 , 461 N.E.2d 64, 71 .) There would thus appear to be two major prerequisites necessary: appropriate qualifications of the expert and a requirement that the jury may be assisted by testimony regarding knowledge beyond that which they would ordinarily have.

11989–1989
People v. Park green
ill · 1978
1 sentence

1979Once the fact of such license has been established, it lies within the sound discretion of the trial court to determine if the witness is qualified to testify as an expert regarding the standard of care. ( People v. Park (1978), 72 Ill.2d 203, 209 .) We recognize that a physician or surgeon may also be a licensed podiatrist and may be sufficiently qualified to testify as to the standard of care owed by podiatrists.

11979–1979

Statutes the citing opinions construe

IL § 720 ILCS 5/9-1 (3) IL § 735 ILCS 5/2-622 (3) IL § 735 ILCS 5/8-2501 (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

TX 59 (1993–2026) IL 44 (1979–2025) CA 37 (1948–2025) GA 30 (1976–2024) NY 25 (1965–2025) OH 21 (1986–2025) PA 21 (1976–2026) NJ 17 (1951–2026) MD 15 (1962–2025) AL 14 (1975–2002) UT 12 (1987–2025) WA 12 (1989–2019) FL 12 (1990–2019) LA 12 (1989–2021) CT 11 (1970–2025) MI 11 (2014–2026) VA 11 (1981–2026) KS 8 (1936–2021) WV 7 (1991–2024) NC 7 (1984–2021) WI 6 (1999–2022) AZ 6 (2005–2022) MS 6 (1986–2020) DC 5 (1997–2009) SC 5 (1987–2025) IA 5 (1976–2017) TN 4 (2004–2025) KY 4 (2003–2017) CO 4 (1984–2025) MT 4 (2002–2020) MN 4 (2003–2024) OK 4 (2001–2026) SD 4 (1980–2014) VT 3 (2010–2016) NV 3 (2007–2021) NH 3 (1998–2024) OR 3 (1988–2013) MO 3 (1985–2015) ND 3 (1979–2007) NE 2 (2015–2025) NM 2 (2011–2014) AR 2 (1989–2025) DE 2 (2001–2025) WY 2 (1981–2001) RI 2 (1988–2002) IN 2 (1982–1990) MA 2 (2016–2017)

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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