3 Ill. 2d 487 - People v. Lueder’s Empirical Analysis
1954
Citation profile
66 state decisions
How this case has been cited
Cited by 67 later decisions — most recently October 2024 · most notably 89 Ill. 2d 352 - People v. Willingham (1982), 138 Ill. 2d 434 - People v. Furby (1990)
66 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 Carlton v. People · Campbell v. People · Bergen v. People · The People v. Nachowicz · 2 Ill. 2d 190 - People v. Gavurnik
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 67 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““ ‘While it has been held that a defendant’s confession, when the corpus delicti is not otherwise proved, is insufficient for a conviction, this does not mean that the corpus delicti must be proved by the evidence, aside from the confession, beyond a reasonable doubt. On the contrary, it was early held that it is the mere naked confession, uncorroborated by any circumstance inspiring belief in its truth arising out of the conduct of the accused or otherwise, which is held insufficient to convict, and the corroborating fact or facts in proof need not necessarily, independent of the confession, tend to prove the corpus delicti. (Bergen v. People, 17 Ill. 426 .) Direct and positive evidence is unnecessary to prove the corpus delicti, (Campbell v. People, 159 Ill. 9 ,) and it is not essential that it should be established by evidence independent of that which tends to connect the accused with its perpetration. The same evidence which tends to prove one may also tend to prove the other, so that the existence of the crime and the guilt of the defendant may stand together inseparable on one foundation of circumstantial evidence. * ° ” (Lueder, 3 Ill. 2d 487, 488 .)”
3 later decisions quote this exact passage · from the majority““[I]n the absence of any evidence independent of the confession clearly showing a crime to have been committed by some person and in the further absence of evidence of other facts or circumstances so fully corroborating the confession as to show the commission of the offense beyond a reasonable doubt, the rule that the corpus delicti cannot be proved by the confession of a defendant alone must be applied.” People v. Lueder (1954), 3 Ill. 2d 487, 489-90 , 121 N.E.2d 743, 744 .”
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.