141 Ill. 2d 394 - People v. Mullen’s Empirical Analysis
1990
Citation profile
146 state decisions
How this case has been cited
Cited by 149 later decisions — most recently November 2025 · most notably 215 Ill. 2d 167 - People v. Herron (2005), 235 Ill. 2d 478 - People v. McLaurin (2009)
146 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 United States v. Young · United States v. Hasting · 122 Ill. 2d 176 - People v. Enoch · 104 Ill. 2d 504 - People v. Albanese · 79 Ill. 2d 564 - People v. Carlson
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 149 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““[t]he main purpose of the plain error rule *** is to protect against the ‘possibility that an innocent person may have been convicted due to some error which is obvious from the record, but not properly preserved’ for appellate review. [Citation.] In cases where the evidence is closely balanced, the probability that a defendant’s conviction was caused by even a minor trial error is greatly enhanced. Therefore, in those cases, the court will invoke the plain error rule so that it can determine whether the error, which was not objected to at trial and in post-trial motions, raises doubt as to the validity of the jury’s verdict.” (Mullen, 141 Ill. 2d at 402 , 566 N.E.2d at 226 .)”
2 later decisions quote this exact passage · from the majority“'And, when you consider that, remember perhaps one of the most powerful things in this case was when [the witness] got up on the stand the first time, and he said he did not want to answer. And use your common sense why he did not want to answer. The same reason that no one wanted to talk, at first; they do not want to get involved. Why don't they want to get involved? They do not want one of these (indicating) in their back. Is this going to be what runs the streets of the City of Chicago?'”
2 later decisions quote this exact passage · from the majority“'[p]rosecutorial comments which suggest that witnesses were afraid to testify because defendant had threatened or intimidated them, when not based upon any evidence in the record * * * are highly prejudicial and inflammatory.'”
2 later decisions quote this exact passage · from the majoritye.g. People v. Green · People v. Davis
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.