205 Ill. 2d 411 - People v. Tenney’s Empirical Analysis
2002
Citation profile
166 state decisions
How this case has been cited
Cited by 174 later decisions — most recently March 2026 · most notably 235 Ill. 2d 213 - People v. Siguenza-Brito (2009), 229 Ill. 2d 584 - People v. Naylor (2008)
166 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 Chambers v. Mississippi · 128 Ill. 2d 1 - People v. Young · 185 Ill. 2d 532 - People v. Smith · 205 Ill. 2d 52 - People v. Caffey · 189 Ill. 2d 99 - People v. Blue
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 174 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“`tempt[] everyone accused of a crime to introduce perjured testimony that a third party, then deceased or beyond the jurisdiction of the court, had declared that he, and not the accused, had committed the crime.'”
2 later decisions quote this exact passage · from the majority““ ‘Chambers did not do away with the hearsay rule. The Supreme Court contemplated that the [trial] judge would be a gatekeeper, that unreliable statements could be excluded. *** It did not abolish the hearsay rule on constitutional grounds.’ Lee v. McCaughtry, 933 F.2d 536, 538 (7th Cir. 1991). Thus, ‘Federal and State courts have expressed the belief that Chambers has not significantly trammeled judicial discretion to exclude unreliable declarations against penal interest.’ Commonwealth v. Carr, 373 Mass. 617, 625 , 369 N.E.2d 970, 975 (1977).” Tenney, 205 Ill. 2d at 435-36 .”
1 later decision quote this exact passage · from the majority“"statement which was at the time of its making so far contrary to the declarant's pecuniary or proprietary interest, or so far tended to subject the declarant to civil or criminal liability, or to render invalid a claim by the declarant against another, that a reasonable person in the declarant's position would not have made the statement unless believing it to be true. A statement tending to expose the declarant to criminal liability and offered in a criminal case is not admissible unless corroborating circumstances clearly indicate the trustworthiness of the statement."”
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.