127 Ill. 2d 499 - People v. Phillips’s Empirical Analysis
1989
Citation profile
1 federal appellate · 250 state decisions
How this case has been cited
Cited by 258 later decisions (2 by the Supreme Court) — most recently April 2025 · most notably 186 Ill. 2d 83 - People v. Evans (1999), 205 Ill. 2d 52 - People v. Caffey (2001)
1 federal appellate · 250 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 Strickland v. Washington · Jackson v. Virginia · Donnelly v. DeChristoforo · Eddings v. Oklahoma · 122 Ill. 2d 176 - People v. Enoch
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 258 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“"[T]his court has long held that it is impermissible for the prosecution to attempt to shift the burden of proof to the defense. [Citation.] Indeed, the defense is under no obligation to present any evidence; 'the prosecution has the burden of proving beyond a reasonable doubt all the material and essential facts constituting the crime.’ [Citation.] This court has never said or implied, however, that once a defendant does present certain evidence it is beyond the reach of appropriate comment by the prosecution. There is a great deal of difference between an allegation by the prosecution that defendant did not prove himself innocent and statements questioning the relevance or credibility of a defendant’s case. [Citations.] Not every prosecutorial statement questioning relevance or credibility rises to an impermissible shifting of the burden.” Phillips, 127 Ill. 2d at 527 , 538 N.E.2d at 511 .”
3 later decisions quote this exact passage · from the majority“A reviewing court will not set aside a criminal conviction on grounds of insufficient evidence unless the proof is so improbable or unsatisfactory that there exists a reasonable doubt of the defendant's guilt. When considering the sufficiency of the evidence, it is not the function of a reviewing court to retry the defendant. Rather, the relevant question is whether, after reviewing all of the evidence in the light most favorable to the prosecution, any rational fact finder could have found beyond a reasonable doubt the essential elements of the crime.”
3 later decisions quote this exact passage · from the majority“[i]mproper comment is plain error [only] when it is either so inflammatory that the defendant could not have received a fair trial or so flagrant as to threaten a deterioration of the judicial process.”
3 later decisions 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.