104 Ill. 2d 375 - People v. Lambert’s Empirical Analysis
1984
Citation profile
124 state decisions
How this case has been cited
Cited by 127 later decisions — most recently February 2026 · most notably 239 Ill. 2d 166 - People v. Sargent (2010), 156 Ill. 2d 483 - People v. Cloutier (1993)
124 state decisions
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Relationships
Relies on 89 Ill. 2d 352 - People v. Willingham · 91 Ill. 2d 22 - People v. Dalton · 18 Ill. 2d 461 - The People v. O'Neil · 3 Ill. 2d 487 - People v. Lueder · 26 Ill. 2d 228 - The PEOPLE v. Perfecto
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 127 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“"Proof of corpus delicti requires both proof of injury or loss, as well as proof of criminal agency. * * * [Citation.] However, the corpus delicti cannot be proved by the defendant's confession alone. [Citations.] There must be either some independent evidence or corroborating evidence outside of the confession which tends to establish that a crime occurred. [Citation.] If there is such evidence, and that evidence tends to prove that the offense occurred, then that evidence, if it corroborates the facts contained in the defendant's confession, may be considered together with the confession to establish the corpus delicti. [Citation.]" (Internal quotation marks omitted.) Id. at 378-79 , 84 Ill. Dec. 467 , 472 N.E.2d 427 .”
3 later decisions quote this exact passage · from the majority““It is a basic concept in criminal law that proof of a criminal offense involves the proof of two distinct propositions or facts beyond a reasonable doubt. First, that a crime was committed, and second, that it was committed by the person or persons charged. In other words, *** ‘the corpus delicti must be proved and the identity of the defendant as the guilty party must be established.’ ””
2 later decisions quote this exact passage · from the majority““[I]n the absence of any evidence independent of the confession clearly showing a crime to have been committed by some person and in the further absence of evidence of other facts or circumstances so fully corroborating the confession as to show the commission of the offense beyond a reasonable doubt, the rule that the corpus delicti cannot be proved by the confession of a defendant alone must be applied.” People v. Lueder (1954), 3 Ill. 2d 487, 489-90 , 121 N.E.2d 743, 744 .”
1 later decision quote this exact passage · from the majority
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.