Case Citation
Legal Case Name

ILLINOIS v. ALLEN Case Brief

Supreme Court of United States1970
397 U.S. 337 90 S.Ct. 1057 25 L.Ed.2d 353 Criminal Procedure Constitutional Law Evidence

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Case Brief Summary & Legal Analysis

General Brief
3 min read

tl;dr: A disruptive defendant was removed from his own trial. The Supreme Court held that the Sixth Amendment right to be present is not absolute and can be forfeited by contumacious conduct that makes continuing the trial impossible.

Legal Significance: Established that a criminal defendant’s Sixth Amendment right to be present at trial is not absolute and can be forfeited by disruptive behavior, granting trial judges discretion to remove the defendant to maintain order and ensure the trial proceeds.

ILLINOIS v. ALLEN Law School Study Guide

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Case Facts & Court Holding

Key Facts & Case Background

The respondent, Allen, was tried in Illinois for armed robbery. During the trial, Allen engaged in extremely disruptive and abusive behavior. He argued with the judge, threatened to harm him, and tore up his counsel’s case file, throwing the papers on the floor. The trial judge repeatedly warned Allen that he would be removed from the courtroom if his disruptive conduct continued. Despite these warnings, Allen persisted. The judge ultimately ordered Allen’s removal from the courtroom for a portion of the State’s case-in-chief. The judge informed Allen that he could return to the courtroom at any time if he promised to conduct himself properly. Allen was brought back into the courtroom on several occasions for identification. After the prosecution rested, Allen agreed to behave and was permitted to be present for the remainder of his trial. The Court of Appeals for the Seventh Circuit, on habeas review, held that Allen’s removal violated his absolute Sixth Amendment right to be present at all stages of his trial.

Court Holding & Legal Precedent

Issue: Can a criminal defendant forfeit their Sixth Amendment right to be present at their own trial by engaging in conduct so disorderly and disruptive that the trial cannot be carried on with them in the courtroom?

Yes. The Court held that Allen forfeited his Sixth Amendment right to Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua. Ut enim ad minim veniam, quis nostrud exercitation ullamco laboris nisi ut aliquip ex ea commodo consequat. D

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IRAC Legal Analysis

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Legal Issue

Can a criminal defendant forfeit their Sixth Amendment right to be present at their own trial by engaging in conduct so disorderly and disruptive that the trial cannot be carried on with them in the courtroom?

Conclusion

This landmark decision establishes that the fundamental right to be present at Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua. Ut enim ad minim veniam, qu

Legal Rule

A defendant can lose their Sixth Amendment right to be present at Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua. Ut enim ad minim veniam, quis nostrud exercitation ullamco laboris nisi ut aliquip ex ea commodo consequat. Duis aute irure dolor in reprehenderit in vol

Legal Analysis

The Supreme Court reversed the Court of Appeals, holding that the Sixth Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua. Ut enim ad minim veniam, quis nostrud exercitation ullamco laboris nisi ut aliquip ex ea commodo consequat. Duis aute irure dolor in reprehenderit in voluptate velit esse cillum dolore eu fugiat nulla pariatur. Excepteur sint occaecat cupidatat non proident, sunt in culpa qui officia deserunt mollit anim id est laborum. Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua. Ut enim ad minim veniam, quis nostrud exercitation ullamco laboris nisi ut aliquip ex ea commodo consequat. Duis aute irure dolor in reprehenderit in voluptate velit esse cillum dolore eu fugiat nulla pariatur. Excepteur sint occaecat cupidatat non proident, sunt in culpa qui officia deserunt mollit anim id est laborum. Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua. Ut enim ad minim veniam, quis nostrud exercitation ullamco laboris nisi ut aliquip ex ea commodo consequat. Duis aute irure dolor in reprehenderit in voluptate velit esse cillum dolore eu fugiat nulla pariatur. Excepteur sint occaecat cupidatat non proident, sunt in culpa qui officia deserunt mollit anim id est laborum. Lorem ipsum dolor sit amet, cons

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Flash Summary

  • A defendant’s Sixth Amendment right to be present at trial is
Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua. Ut enim ad minim veniam, quis nostrud exercitation ullamco laboris nisi ut aliquip ex ea commodo consequat. Duis aute irure dolor in reprehend

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