Lyon instruction in Illinois

2021See In re P.S., 2021 IL App (5th) 210027 ; Vazquez Diaz, 167 N.E.3d at 840-41; In re A.B., 956 N.W.2d at 170-71; In re TJH, 2021 WY 56, ¶ 22 , 485 P.3d at 415-16 . ¶ 16 W.L. argues that the trial court should have granted his motion for a continuance to wait and see whether a vaccine would permit the court to hear the case with the parties and the witnesses present in court.

2021See In re P.S., 2021 IL App (5th) 210027 ; Vazquez Diaz, 167 N.E.3d at 840-41; In re A.B., 956 N.W.2d at 170-71; In re TJH, 2021 WY 56, ¶ 22 , 485 P.3d at 415-16 . ¶ 16 W.L. argues that the trial court should have granted his motion for a continuance to wait and see whether a vaccine would permit the court to hear the case with the parties and the witnesses present in court.

2020An example of this approach is People v. Robinson, 73 Ill. 2d 192 (1978), in which the defendant appealed the substantive admission of a rape victim’s out-of-court statements that were consistent with her testimony that the defendant sexually assaulted her.

2020An example of this approach is People v. Robinson, 73 Ill. 2d 192 (1978), in which the defendant appealed the substantive admission of a rape victim’s out-of-court statements that were consistent with her testimony that the defendant sexually assaulted her.

2009However, *** the Act further contains the overall requirement that proceedings following a summary suspension be ‘promptly instituted and determined.’ Accordingly, we address the other Mallen factors, the importance of the private interest and the government’s justification for the delay, in light of Lyon’s instruction that where an agency uses a lower standard of proof to support a prehearing deprivation, the necessity of acting promptly is heightened.” Morgan I, 374 Ill.

2009However, * * * the Act further contains the overall requirement that proceedings following a summary suspension be `promptly instituted and determined' Accordingly, we address the other Mallen factors, the importance of the private interest and the government's justification for the delay, in light of Lyon's instruction that where an agency uses a lower standard of proof to support a prehearing deprivation, the necessity of acting promptly is heightened." Morgan, 374 Ill.App.3d at 302 , 312 Ill.Dec. 778 , 871 N.E.2d at 200 .

1992The language that we have emphasized — along with the citation to Walski’s discussion of those situations where expert testimony is not necessary because the common knowledge of lay people is sufficient to establish the standard of care and any deviation therefrom — convinces us that our supreme court has rejected the Kolanowski rationale in favor of the Lyon rule that section 2 — 622 applies even in cases of “gross negligence” or “common treatment” (see Walski, 72 Ill. 2d at 256-57 ) as long as these cases involve “medical, hospital or other healing art malpractice.” Put differently, there ar

1992The language that we have emphasized — along with the citation to Walski’s discussion of those situations where expert testimony is not necessary because the common knowledge of lay people is sufficient to establish the standard of care and any deviation therefrom — convinces us that our supreme court has rejected the Kolanowski rationale in favor of the Lyon rule that section 2 — 622 applies even in cases of “gross negligence” or “common treatment” (see Walski, 72 Ill. 2d at 256-57 ) as long as these cases involve “medical, hospital or other healing art malpractice.” Put differently, there ar