161 Ill. 2d 82 - People v. Erickson’s Empirical Analysis
1994
Citation profile
9 federal appellate · 61 state decisions
How this case has been cited
Cited by 93 later decisions — most recently March 2026 · most notably 183 Ill. 2d 366 - People v. Coleman (1998), 187 Ill. 2d 418 - People v. West (1999)
9 federal appellate · 61 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 · 104 Ill. 2d 504 - People v. Albanese · United States v. Eichman · Refre v. United States · 153 Ill. 2d 264 - People v. Flores
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 93 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[T]he default may not preclude an ineffective-assistance claim for what trial counsel allegedly ought to have done in presenting a de- fense. [Citations.] An ineffective-assistance claim based on what the record on direct appeal discloses counsel did, in fact, do is, of course subject to the usual procedural default rule. [Citation.] But a claim based on what ought to have been done may depend on proof of matters which could not have been included in the record precisely because of the allegedly deficient representation. [Cita- tion.]”
6 later decisions quote this exact passage · from the majority““[D]efendant, then 25 years old, enlisted the aid of two juveniles to methodically chart a plan to isolate, bind, and gag a 15-year-old girl for purposes of raping her, stabbing her to death, and, in the end, concealing the corpse. (See Erickson, 117 Ill. 2d at 279-83 .) For those crimes, defendant was remorseless. He bragged about the stabbing immediately after the deed. He boasted of the crimes days after and even did so much later when detained in a county jail awaiting trial. Other aggravating evidence, including the commission of another rape at knife point and a third threatened one, attests to some pattern of sexual assault against women. Any laxity of counsel notwithstanding, what is offered to bolster the ineffectiveness claim does not show the result would ‘reasonably likely’ have been different excluding the possibility of arbitrariness. Briefly, the psychologists’ reports could, at best, only suggest what may have explained defendant’s criminal behavior of July of 1982. The evaluations were produced years after the crimes and, apparently, without the aid of the trial record, which revealed, through witnesses’ testimony, defendant’s actual behavior. The affidavits of the teachers, one from fourth grade and one from high school, disclose that neither maintained close contact with defendant after he left their respective classrooms. And, if anything, they show defendant to be polite, intelligent, and engaging, not a person troubled by a disturbed psyche which might a”
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.