People v. Coleman, 2013 IL 113307

1994 Peoria home invasion: six men robbed residents, beat victims, and Tekelia (17) was sexually assaulted.
Tequilla identified Coleman in photos and lineup; Coats and Nixon were arrested at the scene.
Coleman was convicted of home invasion, aggravated criminal sexual assault, armed robbery, and residential burglary based on testimony and identification.
Postconviction petitions: successive petitions denied; 2009 petition raised actual innocence with new affidavits from several associates.
2013 Supreme Court reversed lower courts, held Washington standard governs actual-innocence claims in Illinois postconviction proceedings, and remanded for a new trial.
Evidence at evidentiary hearing: five witnesses (Coats, Lee, Deondre, Robert, McKay) admitted involvement in the crime but claimed Coleman was not present; their testimony was new, material, noncumulative and potentially exculpatory.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Washington governs actual-innocence claims in Illinois postconviction relief	Coleman favors Washington standard	State seeks enhanced Schlup-based standard	Washington standard applies; not adopted Schlup-esque standard
Whether the new evidence is sufficient to warrant relief under Washington	New, material, noncumulative evidence undermines trial verdict	Evidence should be considered but may be cumulative or not probative	Yes; the new witnesses' testimony is new, material, noncumulative and probably would change retrial outcome
Whether the trial court’s decision denying relief was manifestly erroneous	Evidence viewed in light of new testimony undermines verdict	Trial court properly weighed credibility and sufficiency	Yes; denial was manifestly erroneous under Washington standard
How to apply Washington’s factors to determine probable change in result on retrial	Consider credibility shifts and corroboration from new witnesses	State's evidentiary framework remains credible	Five new witnesses’ testimony, combined with trial record, likely changes result on retrial

Washington v. Illinois, 171 Ill. 2d 475 (1996) (establishes Illinois standard for actual-innocence claims in postconviction relief)
Molstad v. Molstad, 101 Ill. 2d 128 (1984) (new, material, noncumulative evidence required for relief)
Silagy v. Molstad, 116 Ill. 2d 357 (1987) (evidence must be noncumulative; substantial change in confidence in verdict)
Stovall v. State, 47 Ill. 2d 42 (1970) (burden of proof in postconviction hearings is by a preponderance of the evidence)
Burrows v. City of Springfield, 172 Ill. 2d 169 (1996) (establishes procedural context for actual-innocence relief)
People v. Caballes, 221 Ill. 2d 282 (2006) (discusses Washington modification of lockstep approach)