common-criminal-design rule (Illinois) · Go Syfert
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common-criminal-design rule in Illinois

5 Illinois opinions name it 1 courts 2017–2021 1 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 (6)

CaseFollowedCited
People v. Fernandezgreen
ill · 2014 · cited in 5 Illinois opinions naming this issue, 2017–2021
2 sentences

2021Under the common-criminal-design rule, if “ ‘two or more persons engage in a common criminal design or agreement, any acts in the furtherance - 14 - of that common design committed by one party are considered to be the acts of all parties to the design or agreement and all are equally responsible for the consequences of the further acts.’ ” Fernandez, 2014 IL 115527, ¶ 13 (quoting In re W.C., 167 Ill. 2d 307, 337 (1995)).

2021“It is the fact that the defendant and a co-offender had a common criminal design to begin with that makes [her] responsible for any act in furtherance of that criminal design.” People v. Wilson, 2020 IL App (1st) 162430, ¶ 67 (citing 720 ILCS 5/5-2(c) (West 2012)). ¶ 64 In Fernandez, 2014 IL 115527 , ¶ 14, our supreme court observed that a “textbook application” of the common-criminal-design rule occurred in People v. Kessler, 57 Ill. 2d 493 (1974).

25
People v. Johnsongreen
ill · 1973 · cited in 2 Illinois opinions naming this issue, 2020–2021
2 sentences

2021As our supreme court said long ago, “[w]here murder is committed during a robbery, all participants in the robbery are deemed equally guilty of murder and it is immaterial who fired the fatal shot.” (Internal quotation marks omitted.) People v. Johnson, 55 Ill. 2d 62, 67 (1973).

2020As our supreme court said long ago, “[w]here murder is committed during a robbery, all participants in the robbery are deemed equally guilty of murder and it is immaterial who fired the fatal shot.” (Internal quotation marks omitted.) People v. Johnson, 55 Ill. 2d 62, 67 (1973).

22
People v. Perezgreen
ill · 2000 · cited in 2 Illinois opinions naming this issue, 2020–2021
2 sentences

2021In Fernandez, 2014 IL 115527, ¶ 16 , our supreme court highlighted the holding of Kessler and noted, “[i]n other words, once [the defendant in Kessler] agreed to participate in burglary, he was liable under [the accountability statute] for every criminal act committed ‘in connection therewith,’ including the unplanned shootings committed by his initially unarmed companions.” As such, under the common-criminal-design rule, as discussed in Fernandez and - 15 - Kessler, a “defendant cannot escape liability merely because his criminal intentions did not rise to the level of murder.” Phillips, 2014

2020In Fernandez, 2014 IL 115527, ¶ 16 , our supreme court highlighted the holding of Kessler and noted, “[i]n other words, once [the defendant in Kessler] agreed to participate in burglary, he was liable under [the accountability statute] for every criminal act committed ‘in connection - 27 - No. 1-16-3245 therewith,’ including the unplanned shootings committed by his initially unarmed companions.” As such, under the common-criminal-design rule, as discussed in Fernandez and Kessler, a “defendant cannot escape liability merely because his criminal intentions did not rise to the level of murder.”

22
In Re WCgreen
ill · 1995 · cited in 2 Illinois opinions naming this issue, 2020–2021
2 sentences

2021Under the common-criminal-design rule, if “ ‘two or more persons engage in a common criminal design or agreement, any acts in the furtherance - 14 - of that common design committed by one party are considered to be the acts of all parties to the design or agreement and all are equally responsible for the consequences of the further acts.’ ” Fernandez, 2014 IL 115527, ¶ 13 (quoting In re W.C., 167 Ill. 2d 307, 337 (1995)).

2021In Fernandez, 2014 IL 115527, ¶ 16 , our supreme court highlighted the holding of Kessler and noted, “[i]n other words, once [the defendant in Kessler] agreed to participate in burglary, he was liable under [the accountability statute] for every criminal act committed ‘in connection therewith,’ including the unplanned shootings committed by his initially unarmed companions.” As such, under the common-criminal-design rule, as discussed in Fernandez and - 15 - Kessler, a “defendant cannot escape liability merely because his criminal intentions did not rise to the level of murder.” Phillips, 2014

22
People v. Wilsongreen
illappct · 2020 · cited in 2 Illinois opinions naming this issue, 2020–2021
2 sentences

2021“It is the fact that the defendant and a co-offender had a common criminal design to begin with that makes [her] responsible for any act in furtherance of that criminal design.” People v. Wilson, 2020 IL App (1st) 162430, ¶ 67 (citing 720 ILCS 5/5-2(c) (West 2012)). ¶ 64 In Fernandez, 2014 IL 115527 , ¶ 14, our supreme court observed that a “textbook application” of the common-criminal-design rule occurred in People v. Kessler, 57 Ill. 2d 493 (1974).

2020“It is the fact that the defendant and a co-offender had a common criminal design to begin with that makes [her] responsible for any act in furtherance of that criminal design.” People v. Wilson, 2020 IL App (1st) 162430, ¶ 67 (citing 720 ILCS 5/5-2(c) (West 2012)). ¶ 64 In Fernandez, 2014 IL 115527 , ¶ 14, our supreme court observed that a “textbook application” of the common-criminal-design rule occurred in People v. Kessler, 57 Ill. 2d 493 (1974).

22
People v. Kesslergreen
ill · 1974 · cited in 3 Illinois opinions naming this issue, 2018–2021
2 sentences

2021“It is the fact that the defendant and a co-offender had a common criminal design to begin with that makes [her] responsible for any act in furtherance of that criminal design.” People v. Wilson, 2020 IL App (1st) 162430, ¶ 67 (citing 720 ILCS 5/5-2(c) (West 2012)). ¶ 64 In Fernandez, 2014 IL 115527 , ¶ 14, our supreme court observed that a “textbook application” of the common-criminal-design rule occurred in People v. Kessler, 57 Ill. 2d 493 (1974).

2020“It is the fact that the defendant and a co-offender had a common criminal design to begin with that makes [her] responsible for any act in furtherance of that criminal design.” People v. Wilson, 2020 IL App (1st) 162430, ¶ 67 (citing 720 ILCS 5/5-2(c) (West 2012)). ¶ 64 In Fernandez, 2014 IL 115527 , ¶ 14, our supreme court observed that a “textbook application” of the common-criminal-design rule occurred in People v. Kessler, 57 Ill. 2d 493 (1974).

13

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. Phillips green
illappct · 2014
2 sentences

2021In Fernandez, 2014 IL 115527, ¶ 16 , our supreme court highlighted the holding of Kessler and noted, “[i]n other words, once [the defendant in Kessler] agreed to participate in burglary, he was liable under [the accountability statute] for every criminal act committed ‘in connection therewith,’ including the unplanned shootings committed by his initially unarmed companions.” As such, under the common-criminal-design rule, as discussed in Fernandez and - 15 - Kessler, a “defendant cannot escape liability merely because his criminal intentions did not rise to the level of murder.” Phillips, 2014

2020In Fernandez, 2014 IL 115527, ¶ 16 , our supreme court highlighted the holding of Kessler and noted, “[i]n other words, once [the defendant in Kessler] agreed to participate in burglary, he was liable under [the accountability statute] for every criminal act committed ‘in connection - 27 - No. 1-16-3245 therewith,’ including the unplanned shootings committed by his initially unarmed companions.” As such, under the common-criminal-design rule, as discussed in Fernandez and Kessler, a “defendant cannot escape liability merely because his criminal intentions did not rise to the level of murder.”

22020–2021
People v. Murray green
illappct · 2017
2 sentences

2018In essence, the State theorized that when Hernandez shot Herman, defendant was equally responsible, because the shooting was done in furtherance of the - 14 ­ 2017 IL App (2d) 150599 common criminal design to inflict violence.

2018Defendant ignores the substantial evidence that inculpated him under the common-criminal-design rule. - 15 ­ 2017 IL App (2d) 150599 this, because after Hernandez got the gun, Cox told Herman to shut up.

12018–2018

Statutes the citing opinions construe

IL § 720 ILCS 5/9-1 (5) IL § 720 ILCS 5/24-1.6 (3) IL § 720 ILCS 5/24-1.8 (3) IL § 720 ILCS 5/5-2 (3) IL § 725 ILCS 5/115-10.1 (3) IL § 740 ILCS 147/10 (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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