203 Ill. 2d 352 - People v. Thurow’s Empirical Analysis
2003
Citation profile
6 federal appellate · 206 state decisions
How this case has been cited
Cited by 220 later decisions — most recently January 2026 · most notably 215 Ill. 2d 167 - People v. Herron (2005), 214 Ill. 2d 455 - People v. Woods (2005)
6 federal appellate · 206 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 Apprendi v. New Jersey · Chapman v. State of California · United States v. Olano · In the Matter of Samuel Winship · Gideon v. Wainwright
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 220 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“"Though plain-error analysis normally requires the same kind of inquiry as does harmless-error review, there is an `important difference' between the two. United States v. Olano, 507 U.S. 725, 734 , 113 S.Ct. 1770, 1778 , 123 L.Ed.2d 508, 520 (1993). In a harmless-error analysis, which applies where, as in the case at bar, the defendant has made a timely objection, it is the State that `bears the burden of persuasion with respect to prejudice.' Olano, 507 U.S. at 734 , 113 S.Ct. at 1778 , 123 L.Ed.2d at 520 . In other words, the State must prove beyond a reasonable doubt that the jury verdict would have been the same absent the error. See Chapman v. California, 386 U.S. 18, 24 , 87 S.Ct. 824, 828 , 17 L.Ed.2d 705, 710-11 (1967); Neder v. United States, 527 U.S. 1, 19 , 119 S.Ct. 1827, 1838 , 144 L.Ed.2d 35, 53 (1999). The situation is different under a plain-error analysis, which applies where the defendant has failed to make a timely objection. There, `[i]t is the defendant rather than the [State] who bears the burden of persuasion with respect to prejudice.' Olano, 507 U.S. at 734 , 113 S.Ct. at 1778 , 123 L.Ed.2d at 520 . `In most cases, a court of appeals cannot correct the forfeited error unless the defendant shows that the error was prejudicial.' Olano, 507 U.S. at 734 , 113 S.Ct. at 1778 , 123 L.Ed.2d at 520 ." Thurow, 203 Ill.2d at 363 , 272 Ill.Dec. 185 , 786 N.E.2d 1019 .”
6 later decisions quote this exact passage · from the majority“`the fairness, integrity, or public reputation of judicial proceedings.'”
6 later decisions quote this exact passage · from the majority“"There is no indication here as to the evidentiary standard that is to be applied in making the household-member determination. Under section 9-3(f), this finding could be made by a preponderance of the evidence. However, it also could be made based upon proof beyond a reasonable doubt. Under Apprendi , a finding, based upon a preponderance of the evidence, that the victim was a member of defendant's household could not form the basis for an enhanced sentence. As noted, such a procedure would be unconstitutional. However, there is no violation if this determination is made beyond a reasonable doubt. Because this latter, constitutionally correct procedure is allowed by section 9-3(f), it cannot be said that there is no set of circumstances under which the statute would be valid. See In re C.E., 161 Ill.2d [200,] 210-11[, 204 Ill.Dec. 121 , 641 N.E.2d 345, 350 (1994)]. Section 9-3(f) is not unconstitutional on its face. Accordingly, we reject defendant's contention that section 9-3(f) is void ab initio. " Thurow, 203 Ill.2d at 368 , 272 Ill.Dec. 185 , 786 N.E.2d at 1028 .”
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.