2020 IL App (1st) 170295
Ill. App. Ct.2020Background
- On Jan. 22, 1999, Veronica Riley was fatally shot outside a convenience store; eyewitness Tara Coleman initially identified Harold Blalock as the shooter from a black Pontiac but later recanted at trial.
- Blalock gave a handwritten, signed confession stating he fired at a man named Banks from Marcus Carpenter’s car; the confession was memorialized in the presence of detectives and an assistant state’s attorney.
- Before trial Blalock moved to suppress the confession, alleging physical coercion (yelling, slapping, fingernail-splitting, gun to head); detectives and the ASA denied misconduct and the motion was denied.
- At trial Blalock admitted making the statement but testified he fabricated it to appease detectives (not that he was physically coerced); a jury convicted him of first-degree murder and he received 40 years. Direct appeal and two prior postconviction petitions were unsuccessful.
- In 2016 Blalock filed a third postconviction petition alleging his confession was coerced and attaching misconduct allegations against the detectives; the trial court denied leave to file the successive petition under the cause-and-prejudice test.
- The appellate court affirmed, holding Blalock failed to show cause for not raising the coerced-confession claim earlier, his own trial testimony and prior suppression hearing undercut the new claim, and his Brady argument failed.
Issues
| Issue | Plaintiff's Argument (People) | Defendant's Argument (Blalock) | Held |
|---|---|---|---|
| Whether Blalock showed "cause and prejudice" to permit a successive postconviction petition alleging his confession was coerced | Blalock knew the factual basis earlier and could have raised the claim on direct appeal or in earlier petitions; no objective impediment; claim is waived/res judicata; record (suppression hearing, trial testimony) rebuts coercion | New corroborating evidence (reports, affidavits, IA memos, press reports) about the detectives’ misconduct became available only recently and establishes cause; coerced confession deprived due process | Denied — Blalock failed to show cause; the coerced-confession claim was available earlier and is contradicted by his own testimony and prior suppression hearing findings |
| Whether the State violated Brady by failing to disclose detectives’ alleged misconduct history | No Brady violation: defense could have discovered and used such evidence earlier; Blalock’s trial testimony undermines materiality; Orange controls | Failure to disclose detectives’ history was material and would have supported a coerced-confession defense or changed trial strategy | Denied — Brady claim rejected; appellate court bound by precedent and found no basis to overturn given the record and Blalock’s testimony |
Key Cases Cited
- Miranda v. Arizona, 384 U.S. 436 (establishing Miranda warnings and custodial interrogation protections)
- Brady v. Maryland, 373 U.S. 83 (suppression of favorable, material evidence by the State violates due process)
- People v. Hodges, 234 Ill. 2d 1 (postconviction proceedings permit collateral attack on constitutional claims not adjudicated on direct appeal)
- People v. Edwards, 2012 IL 111711 (res judicata and waiver bar postconviction claims that were or could have been raised earlier)
- People v. Orange, 168 Ill. 2d 138 (treatment of postconviction claims and reviewability; on Brady-related arguments)
- People v. Wrice, 406 Ill. App. 3d 43 (permitting successive petition where petitioner consistently alleged coercion and new evidence supported cause)
- People v. Williams, 394 Ill. App. 3d 236 (postconviction claim availability and disclosure obligations)
- People v. Anderson, 375 Ill. App. 3d 990 (evaluating whether previously available evidence supports successive postconviction claims)