Illinois Appellate Court: 2026 IL App (4th) 251240-U Is Non-Precedential

• The Illinois Fourth District Appellate Court issued an order in *People v. Hawkins* on September 2, 2026.
• The order, cited as 2026 IL App (4th) 251240-U, was filed by clerk Carla Bender.
• This ruling was issued under Supreme Court Rule 23, meaning it is generally not considered precedential.
• Under Rule 23(e)(1), the order can be cited in limited circumstances, such as for res judicata or collateral estoppel, and also for persuasive purposes if issued on or after January 1, 2021.
• Non-precedential orders do not establish binding legal authority for future, unrelated cases.

The designation "not precedent" signifies that the legal reasoning and conclusions presented in such an order are not to be cited as authoritative legal principles in other, unrelated litigation.

The Illinois Fourth District Appellate Court recently issued an order in the case of *People v. Hawkins*, which has been assigned the official citation 2026 IL App (4th) 251240-U. This particular ruling was formally filed on September 2, 2026, with Carla Bender, the court's clerk, overseeing its official entry into the judicial record. The document explicitly states that it was processed under the specific provisions of Supreme Court Rule 23.

A defining characteristic of this order, as clearly indicated on the document itself, is its non-precedential status. This designation means that, under normal circumstances, the decision and its underlying reasoning in *People v. Hawkins* do not establish binding legal authority that must be followed by other courts in future, unrelated cases. The ability to cite such an order is strictly circumscribed; while not precedential, orders issued on or after January 1, 2021, may be cited for persuasive purposes, in addition to the limited situations outlined within Rule 23(e)(1).

Supreme Court Rule 23 governs the publication and precedential value of decisions issued by the Illinois Appellate Court. Its primary purpose is to manage the overwhelming volume of appellate opinions by designating which rulings will serve as binding precedent for subsequent cases and which will not. Orders filed under this rule, like the one in *People v. Hawkins*, are typically reserved for cases that do not establish new legal principles, resolve conflicting precedent, or involve significant public interest.

The designation "not precedent" signifies that the legal reasoning and conclusions presented in such an order are not to be cited as authoritative legal principles in other, unrelated litigation. This distinction is crucial for maintaining a manageable body of binding case law. However, Rule 23(e)(1) allows for citation in specific, narrow exceptions, such as for the law of the case, res judicata, or collateral estoppel, and also permits citation for persuasive purposes for orders issued on or after January 1, 2021.

For legal practitioners, the non-precedential nature of an order like *People v. Hawkins* carries significant implications for how they conduct legal research and construct arguments. Attorneys cannot rely on the specific legal analysis or factual application within this order to argue similar points in different cases, as it does not create a binding rule that lower courts must follow. This encourages lawyers to focus their research on published, precedential opinions that carry the full weight of legal authority, ensuring that their arguments are grounded in established law.

The existence of Rule 23 helps the judiciary operate more efficiently by allowing appellate courts to resolve a high volume of appeals without the burden of crafting every decision into a universally applicable legal treatise. While the outcome of *People v. Hawkins* is final and binding for the specific parties involved in that dispute, its broader impact on the development of Illinois law is intentionally constrained. This system ensures that only the most significant and broadly applicable legal pronouncements contribute to the evolving body of binding precedent, streamlining the legal landscape.

Source: Based on an Illinois Appellate Court filing.