198 Ill. 2d 194 - People v. Anthony’s Empirical Analysis
2001
Citation profile
81 state decisions
How this case has been cited
Cited by 82 later decisions — most recently January 2026 · most notably 203 Ill. 2d 165 - People v. Gherna (2003), 204 Ill. 2d 220 - People v. Gonzalez (2003)
81 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 Terry v. Ohio · Katz v. United States · Schneckloth v. Bustamonte · Ornelas v. United States · Bumper v. North Carolina
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 82 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““ ‘In examining all the surrounding circumstances to determine if in fact the consent to search was coerced, account must be taken of subtly coercive police questions, as well as the possibly vulnerable subjective state of the person who consents.’ [Citation.] *** [T]he State bears the burden of proving the consent was truly voluntary.” Anthony, 198 Ill. 2d at 202 , 761 N.E.2d at 1192 , quoting Schneckloth v. Bustamonte, 412 U.S. 218, 229 , 36 L. Ed. 2d 854, 864 , 93 S. Ct. 2041, 2049 (1973).”
3 later decisions quote this exact passage · from the majority““The defendant may convey consent to search by nonverbal conduct [citations], but ‘mere acquiescence to apparent authority is not necessarily consent’ [citation]. *** The State would have us draw an inference *** that the defendant intended to consent, not acquiesce. An equally valid inference from the defendant’s ambiguous gesture is that he submitted and surrendered to what he viewed as the intimidating presence of an armed and uniformed police officer who had just asked a series of subtly and increasingly accusatory questions.” Anthony, 198 Ill. 2d at 202-03 , 761 N.E.2d at 1192-93 , quoting People v. Kelly, 76 Ill. App. 3d 80, 87 , 394 N.E.2d 739, 744 (1979).”
2 later decisions quote this exact passage · from the majority“Id. ¶ 37 In other cases, courts have found consent not to be voluntary because intimidating or coercive conduct on the part of police led defendants to feel that they had no choice but to consent to the search. In Anthony , for example, the Illinois Supreme Court found an officer's request for consent to search the defendant's person to be coercive due to”
1 later decision quote this exact passage · from the majoritye.g. People v. Hayes
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.