Illinois Appellate Court: 2026 IL App (1st) 242277-U Issued as Rule 23 Non-Precedential

• The Illinois Appellate Court, First District, Sixth Division, issued an order in *People v. Wardlaw* on September 18, 2026, with the citation 2026 IL App (1st) 242277-U.
• This order was filed under Illinois Supreme Court Rule 23, meaning it is generally not considered precedent.
• Despite its non-precedential status, the order may be cited in limited circumstances as permitted by Rule 23(e)(1), including for persuasive purposes for orders issued on or after January 1, 2021.
• Legal practitioners must understand the narrow exceptions under Rule 23(e)(1) before citing such orders in legal arguments.

The notice accompanying the *People v. Wardlaw* order explicitly states that it was filed under Supreme Court Rule 23, indicating its status as an order that is not precedent.

The Illinois Appellate Court, First District, Sixth Division, recently issued an order in the case of *People v. Wardlaw Illinois*. This judicial action, identified by the citation 2026 IL App (1st) 242277-U and case number 1-24-2277, was filed on September 18, 2026. The order, while addressing specific legal matters between the parties involved, carries a particular designation regarding its precedential value, which is crucial for legal practitioners to understand.

This specific filing is noteworthy not for its substantive legal findings, which are not detailed in the public notice, but for its classification under Illinois Supreme Court Rule 23. This rule dictates the precedential weight of certain appellate court decisions, marking them as generally non-binding on future cases. The designation serves as an immediate signal to the legal community about how the order can be utilized in subsequent litigation or legal arguments.

The notice accompanying the *People v. Wardlaw* order explicitly states that it was filed under Supreme Court Rule 23, indicating its status as an order that is not precedent. This rule is a fundamental aspect of Illinois case law citation rules, governing how appellate court decisions are treated within the state's judicial system. Its primary purpose is to manage the volume of published opinions and allow the appellate courts to focus their resources on cases that present novel legal questions or require the development of new legal principles.

Orders issued under Illinois Rule 23 non-precedential status are typically those that apply established law to a particular set of facts, resolve factual disputes, or address issues that do not have broad jurisprudential significance. Consequently, while such orders resolve the dispute between the immediate parties, they are generally not intended to serve as binding authority for other cases. This distinction is vital for attorneys researching and citing Illinois Appellate Court First District decisions.

Despite the general rule that orders filed under Supreme Court Rule 23 are not precedent, the notice for 2026 IL App (1st) 242277-U also highlights a critical caveat: these orders *can* be cited in limited circumstances as allowed under Rule 23(e)(1). This provision outlines specific conditions under which an otherwise non-precedential order may be referenced in legal arguments or filings. Understanding these Rule 23(e)(1) exceptions is paramount for any lawyer practicing in Illinois.

Practitioners must carefully review the precise language of Rule 23(e)(1) to ascertain when citation is permissible. These exceptions are designed to prevent injustice or to allow for the use of an order for purposes such as establishing res judicata, collateral estoppel, or law of the case, or when the order is relevant to a criminal proceeding. Additionally, for nonprecedential orders entered under subpart (b) on or after January 1, 2021, they may be cited for persuasive purposes. The existence of these specific allowances means that while the *People v. Wardlaw* order is broadly non-precedential, its utility is not entirely negated, provided the strictures of Rule 23(e)(1) are met.

For attorneys, the designation of 2026 IL App (1st) 242277-U as an Illinois Rule 23 non-precedential order underscores the necessity of meticulous research and adherence to Illinois case law citation rules. Relying on such an order as binding authority without satisfying the specific exceptions outlined in Rule 23(e)(1) could lead to ineffective legal arguments or even sanctions. The Illinois Appellate Court First District, like other appellate districts, issues numerous orders under this rule, making it a common consideration for legal professionals.

Therefore, when encountering decisions like *People v. Wardlaw*, lawyers are reminded that the default assumption should be non-precedential status. Any attempt to cite or rely upon such an order must be accompanied by a clear justification under one of the enumerated Rule 23(e)(1) exceptions. This ensures the integrity of legal arguments and respects the hierarchical structure of Illinois judicial precedent.

Lawyers must note that this Illinois Appellate Court order is non-precedential under Supreme Court Rule 23, meaning it generally cannot be cited as binding authority. Practitioners should carefully review Rule 23(e)(1) to understand the narrow circumstances where citation is permitted, ensuring proper application in legal arguments.

Source: Original reporting via Illinois Appellate Court filing