67 Ill. 2d 564 - People v. Manion’s Empirical Analysis
1977
Citation profile
667 state decisions
How this case has been cited
Cited by 680 later decisions — most recently March 2026 · most notably 128 Ill. 2d 1 - People v. Young (1989), 101 Ill. 2d 128 - People v. Molstad (1984)
667 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 Neil v. Biggers · Stovall v. Denno · Manson v. Brathwaite · Chambers v. Mississippi · Washington v. Texas
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 680 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“* * the opportunity of the witness to view the criminal at the time of the crime, the witness’ degree of attention, the accuracy of the witness’ prior description of the criminal, the level of certainty demonstrated by the witness at the confrontation, and the length of time between the crime and the confrontation.” (People v. Manion (1977), 67 Ill. 2d 564, 571 , 367 N.E.2d 1313, 1317 , cert. denied (1978), 435 U.S. 937 , 55 L. Ed. 2d 533 , 98 S. Ct. 1513 .)”
11 later decisions quote this exact passage · from the majority““[W]here the identification of the accused is at issue, the testimony of one witness is sufficient to convict, even though such testimony is contradicted by the accused, provided the witness is credible and he viewed the accused under such circumstances as would permit a positive identification to be made.” (People v. Manion (1977) , 67 Ill. 2d 564, 578 , 367 N.E.2d 1313, 1320 , cert, denied (1978) , 435 U.S. 937 , 55 L. Ed. 2d 533 , 98 S. Ct. 1513 .)”
6 later decisions quote this exact passage · from the majoritye.g. People v. Ward · People v. Harris““In Manson, the Supreme Court unequivocally adopted the Stovall *** approach of ‘totality of the circumstances’ and rejected a per se approach to determine the admission of suggestive out-of-court identification evidence. The per se test would exclude identification or confrontation evidence ‘without regard to reliability, whenever it has been obtained through unnecessarily suggested confrontation procedures.’ [Citation.] The Stovall test of totality of the circumstances, on the other hand, ‘permits the admission of the confrontation evidence if, despite the suggestive aspect, the out-of-court identification possesses certain features of reliability.’ [Citation.] In other words, evidence of an unnecessarily suggestive identification may nevertheless be admitted at trial if reliability of the identification, under the totality of circumstances, is shown.””
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.