158 Ill. 2d 191 - People v. Gard’s Empirical Analysis
1994
Citation profile
6 federal appellate · 68 state decisions
How this case has been cited
Cited by 80 later decisions (3 by the Supreme Court) — most recently January 2026 · most notably United States v. Scheffer (1998), 215 Ill. 2d 167 - People v. Herron (2005)
6 federal appellate · 68 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 88 Ill. 2d 225 - People v. Baynes · 149 Ill. 2d 423 - People v. Melock · 94 Ill. 2d 327 - People v. Szabo · 101 Ill. 2d 377 - People v. Taylor · 93 Ill. 2d 421 - People v. Yarbrough
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 80 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“"[t]his court has consistently held evidence pertaining to polygraph examination of a defendant generally inadmissible, declaring unequivocally in People v. Baynes (1981), 88 Ill. 2d 225, 244 [, 430 N.E.2d 1070 ], that such evidence is inadmissible in Illinois because it is insufficiently reliable. Moreover, the court observed [in Baynes], '[n]o other form of evidence is as likely to be considered as completely determinative of guilt or innocence as a polygraph examination.’ (Baynes, 88 Ill. 2d at 244 .) Because the results of polygraph examinations appear to be quasi-scientific, jurors are likely to give such results undue weight. (People v. Taylor (1984), 101 Ill. 2d 377, 391-92 [, 462 N.E.2d 478 ].) As a consequence, the prejudicial effects of polygraph evidence substantially outweigh its probative value. Baynes, 88 Ill. 2d at 244 .” (Gard, 158 Ill. 2d at 201 , 632 N.E.2d at 1031 .)”
2 later decisions quote this exact passage · from the majority“concerning defendant's and her participation in setting a building on fire, testified in behalf of the State. Both the codefendant and Clutter testified several times that they had submitted to polygraph examinations. The defendant raised no objections to this testimony; in fact, he made extensive use of it in cross-examining both witnesses and also in calling Clutter as a witness. On cross-examination, Clutter testified that his answers to questions asked as part of the polygraph examination test were, in general, that he”
2 later decisions quote this exact passage · from the majority“that which [he] spoke until and during his polygraph examination was false; that which he spoke once advised by police that he had failed the polygraph examination was true.” (Gard, 158 Ill. 2d at 203-04 , 632 N.E.2d at 1032 .) The court therefore concluded that the polygraph evidence became the”
2 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.