82 Ill. 2d 250 - People v. Flatt’s Empirical Analysis
1980
Citation profile
111 state decisions
How this case has been cited
Cited by 112 later decisions — most recently February 2025 · most notably 237 Ill. 2d 311 - People v. Givens (2010), 128 Ill. 2d 210 - People v. Shukovsky (1989)
111 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
Applies 18 U.S.C. § 3731
Relies on United States v. Jorn · 82 Ill. 2d 268 - People v. Cox · Examining Board of Engineers v. de Otero · 82 Ill. 2d 234 - People v. Young · 34 Ill. 2d 516 - The PEOPLE v. Braden
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 112 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““Since the right of a defendant to file motions to suppress after the trial has commenced is limited by the provisions of section 114 — 12(c), the State’s right to appeal [the merits of] suppression orders during trial is limited to orders entered allowing these motions.” Flatt, 82 Ill. 2d 250, 264 , 412 N.E.2d 509, 516 .)”
2 later decisions quote this exact passage · from the majority“It is well settled that the precedential scope of a decision is limited to the facts before the court”
2 later decisions quote this exact passage · from the majority“"At common law, a claim that evidence was obtained by means of an illegal search and seizure had to be raised before trial by means of a motion to suppress or to return the evidence. This requirement arose from a consideration of judicial economy; the court should not be required to interrupt a trial in order to determine the collateral issue of the manner in which the evidence was obtained. ( People v. Braden (1966), 34 Ill.2d 516, 520 ; People v. Dalpe (1939), 371 Ill. 607, 611 ; People v. Drury (1929), 335 Ill. 539, 557 ; People v. Brocamp (1923), 307 Ill. 448, 454 .) (See 23A C.J.S. Criminal Law sec. 1060, at 11 (1961).) By virtue of section 114-12(c) (Ill. Rev. Stat. 1977, ch. 38, par. 114-12(c)), the common law rule was relaxed; the court may, in its discretion, conduct a hearing on a motion to suppress even though the motion is filed after trial has begun, providing that it is alleged that the evidence was illegally seized. Thus, the prohibition against filing a motion to suppress during trial has been relaxed so as not to prevail over the constitutional right to be free from unreasonable searches and seizures."”
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.