People v. Adams
2013 IL App (1st) 111081
Ill. App. Ct.2013Background
- Defendant convicted of first degree murder after 2004 trial; sentenced to 45 years.
- Direct appeal upheld; underlying facts summarized in opinion.
- Defendant previously pursued postconviction relief with several petitions; court denied leave.
- In Feb 2011, defendant moved for leave to file a successive postconviction petition based on actual innocence.
- Affidavits from Muhammad Williams, Brigette Rush, and Tijatta Williams claimed another person committed the murder and sought to render defendant innocent.
- Court held Muhammad and Tijatta affidavits constitute newly discovered, material, non-cumulative evidence likely to change retrial outcome; reversed and remanded for postconviction proceedings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the circuit court erred in denying leave for a successive postconviction petition. | Adams argues colorable actual-innocence claim based on new affidavits. | State contends affidavits are not newly discovered or material. | Yes; denial reversed and remanded. |
| Whether Muhammad Williams and Tijatta Williams provided newly discovered evidence. | Affidavits were not available prior to trial and are credible. | Affidavits were not new or material. | Affidavits are newly discovered and material. |
| Whether the affidavits are not merely cumulative and could change retrial results. | Affidavits exonerate defendant and present alternate perpetrator. | Testimony would not change result; conflicts with trial record. | Affidavits are not cumulate and could affect retrial outcome. |
| Whether the affidavits meet the required standard of actual innocence for a colorable claim. | Two affidavits provide total exoneration indicators. | Not enough to establish innocence beyond reasonable doubt. | Two affidavits meet colorable-innocence standard; remand warranted. |
Key Cases Cited
- People v. Edwards, 2012 IL 111711 (Illinois Supreme Court, 2012) (relaxes bar to successive postconviction where actual innocence shown)
- People v. Ortiz, 235 Ill. 2d 319 (Illinois Supreme Court, 2009) (new evidence must be newly discovered and non-cumulative)
- People v. Lofton, 2011 IL App (1st) 100118 (Illinois Appellate Court, 2011) (newly discovered exculpatory evidence can alter retrial expectations)
- People v. Williams, 392 Ill. App. 3d 359 (Illinois Appellate Court, 2009) (non-cumulative exculpatory evidence can create new questions for the trier of fact)
- People v. Green, 2012 IL App (4th) 101034 (Illinois Appellate Court, 2012) (actual innocence evidence must be capable of exonerating)