Supreme Court Summaries
Opinions filed October 3, 2013
People v. Coleman, 2013 IL 113307
Appellate citation: 2011 IL App (3d) 100419-U.
JUSTICE THEIS delivered the judgment of the court, with opinion.
Chief Justice Kilbride and Justices Freeman, Thomas, Garman, Karmeier, and Burke concurred in the judgment and opinion.
In this Peoria County case, the Illinois Supreme Court ordered a new trial for Christopher Coleman, who was convicted by a jury for events which took place when several men entered a house in Peoria in 1994. He was originally sentenced to consecutive terms of 30 years for armed robbery and aggravated criminal sexual assault. The appellate court affirmed on direct appeal, and Coleman was not successful in his initial postconviction claims.
This decision concerns a claim of actual innocence raised in a successive postconviction petition filed in 2009. The circuit court held an evidentiary hearing at which Coleman called eight witnesses and the State called an investigating detective. Coleman’s claim was that he had not been a member of the attacking group.
In this decision, the Illinois Supreme Court said that, in order to succeed on this postconviction claim of actual innocence, the claimant must present new, material, noncumulative evidence that is so conclusive it would probably change the result on retrial. This standard, which is difficult to meet, was announced some time ago in the supreme court’s decision in People v. Washington, 171 Ill. 2d 475 (1996). Although, in this appeal, the State argued for a more rigorous standard with roots in federal law, the Illinois Supreme Court, in this decision, reaffirmed its earlier holding and said that its commitment to Washington is unwavering. Although the State’s evidence at the original trial had been sufficient to convict, there was no forensic evidence linking the postconviction petitioner to the attack, and the identifications which the State did offer were significantly impeached. At the postconviction hearing, Coleman presented the testimony of five men who admitted that they were present at the crime scene and who said that he was not. Although the credibility of three of them could be challenged on retrial because of their voluntary intoxication and of four of them because of their criminal records, their versions of events were remarkedly consistent on certain key details. The State did not dispute that the evidence was new, material and noncumulative.
A circuit court’s decision to deny relief following an evidentiary hearing in such a case is reviewed for manifest error. The supreme court said, in this decision, that the trial court’s ruling that Coleman’s showing was not conclusive enough to probably change the result on retrial was manifestly erroneous.
The supreme court awarded postconviction relief in the form of a new trial, at which the fact finder could, in light of the new evidence, determine the credibility of the witnesses and balance the conflicting eyewitness accounts.