115 Ill. 2d 47 - People v. Beardsley’s Empirical Analysis
1986
Citation profile
7 federal appellate · 39 state decisions
How this case has been cited
Cited by 65 later decisions — most recently September 2025 · most notably American Civil Liberties Union v. Alvarez (2012), 226 Ill. App. 3d 974 - People v. O'TOOLE (1992)
7 federal appellate · 39 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
Applies 18 U.S.C. § 2510 (Electronic Communications Privacy Act of 1986) · 18 U.S.C. § 2511 (Electronic Communications Privacy Act of 1986)
Relies on Lopez v. United States · 56 Ill. 2d 523 - People v. Wright · 34 Ill. 2d 387 - The People v. Kurth · 34 Ill. App. 3d 705 - People v. Klingenberg · 139 Ill. App. 3d 819 - People v. Beardsley
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 65 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““(a) Uses an eavesdropping device to hear or record all or any part of any conversation unless he does so (1) with the consent of all of the parties to such conversation or (2) with the consent of any one party to such conversation and in accordance with Article 108A of the ‘Code of Criminal Procedure of 1963’, approved August 14, 1963, as amended.” Ill. Rev. Stat. 1987, ch. 38, par. 14 — 2(a).”
3 later decisions quote this exact passage · from the majority“[T]he eavesdropping, statute was intended to protect individuals from the surreptitious monitoring of their conversations by the use of eavesdropping devices. * * * The statute is based on the assumption that if the parties to a conversation act under circumstances which entitle them to believe that the conversation is private and cannot be heard by others who are acting in a lawful manner, then they should be protected in their privacy.”
2 later decisions quote this exact passage · from the majority““The primary factor in determining whether the defendant in this case committed the offense of eavesdropping is not, as the appellate court reasoned, whether all of the parties consented to the recording of the conversation. Rather, it is whether the officers/declarants intended their conversation to be of a private nature under circumstances justifying such expectation. The evidence at trial established that, while waiting for the tow truck, Deputy Page and Sergeant Hunt sat in the front seat of Deputy Page’s squad car and conversed. As they spoke, the defendant, who was sitting in the rear seat of the squad car, recorded their conversation. According to the officers’ testimony, neither one of them gave the defendant his consent to record their conversation. The officers also indicated that they did not know the defendant was taping their conversation. However, it seems logical that if the officers intended their conversation to be entirely private, then they would have left the squad car instead of carrying on their conversation in the defendant’s presence. Thus, under the circumstances, the officers cannot be heard to allege that they intended their conversation to be private. Because there was no surreptitious interception of a communication intended by the declarants to be private, secret, or confidential, under circumstances justifying such expectation, there was no violation of the eavesdropping statute.” (Emphasis added.) Beardsley, 115 Ill. 2d at 54-55 , 503 N.E.2d a”
1 later decision quote this exact passage · from the majoritye.g. People v. Herrington
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.