159 Ill. App. 3d 483 - People v. Phillips’s Empirical Analysis
1987
Citation profile
18 state decisions
How this case has been cited
Cited by 18 later decisions — most recently October 2000
18 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 82 Ill. 2d 268 - People v. Cox · 103 Ill. 2d 192 - People v. Jordan · 84 Ill. 2d 400 - People v. Conover · 22 Ill. 2d 175 - The People v. Poland · 124 Ill. App. 3d 363 - People v. Harbold
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 18 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““Elapsed time alone does not control the admissibility of a statement as a spontaneous declaration. The critical factor is the opportunity to fabricate. (People v. Sanchez (1982), 105 Ill. App. 3d 488 , 434 N.E.2d 395 .) The trial court must look to the surrounding circumstances to determine whether there was an opportunity for reflection and invention. People v. Chatman (1982), 110 Ill. App. 3d 19 , 441 N.E.2d 1292 . This court has recognized that the stress of a sexual assault upon a child will remain with the child long after it occurred, and that the child’s statements will be unfabricated for three reasons: (1) the child is apt to repress the incident; (2) it is often unlikely the child will discuss such a stressful incident with anyone but the mother; and (3) the characteristics of young children work to produce declarations free of conscious fabrication for a longer period after the incident than adults. People v. Bitter (1986), 146 Ill. App. 3d 477 , 497 N.E.2d 137 . In Bitter, the two female victims, aged five and three, were awakened during the night by their mother, who had become suspicious that someone had been molesting her children. In response to their mother’s questions, each child indicated that she had been molested. The trial court permitted the mother to repeat the children’s answers at trial. On appeal, this court upheld the admission of the children’s statements as spontaneous declarations, even though the time lapse between the declarations and the mol”
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.