People v. Edwards, 360 Ill. Dec. 784

Edwards was convicted of first-degree murder under accountability, based on a statement admitted at trial made when he was 15; the statement alleged gang-related planning and shooting and was not supported by eyewitness or physical evidence at trial.
Petitioner's trial counsel unsuccessfully moved to suppress his statement as involuntary; he did not testify and presented no defense evidence.
The direct appeal affirmed the conviction; postconviction petitions followed in 2002 (initial), 2006 (second, alleging innocence with a new affidavit from codefendant Eddie Coleman), 2006 denial and 2008 (third) with Eddie Coleman affidavit, and 2008 (fourth) with alibi affidavits from Dominique and Kathleen Coleman.
The appellate court consolidated the third and fourth petitions and affirmed the denials, applying the cause-and-prejudice test.
The Illinois Supreme Court adopts a colorable-claim of actual innocence standard for leave to file successive petitions and holds the alibi affidavits were not newly discovered evidence or sufficient to establish innocence; Eddie Coleman’s affidavit, though newly discovered, did not exonerate Edwards to the required degree.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Standard for leave to file successive petitions	Edwards: should use the initial-stage frivolous/merit standard	People: Ortiz allows actual-innocence basis to relax bar	Colorable-claim of actual innocence standard applies
Newly discovered evidence status of Coleman affidavits	Coleman affidavits are newly discovered	Most affidavits were not; only Eddie Coleman potentially newly discovered	Dominique/Kathleen affidavits not newly discovered; Eddie Coleman could be, but not conclusive
Whether the new evidence establishes actual innocence	New evidence would likely lead to acquittal	Evidence not conclusive; could not change result	No colorable claim of actual innocence; leave to file denied

People v. Ortiz, 235 Ill. 2d 319 (2009) (actual innocence may excuse the bar to successive petitions)
People v. Pitsonbarger, 205 Ill. 2d 444 (2002) (two bases to relax bar; cause-and-prejudice and miscarriage of justice)
Szabo v. Szabo, 186 Ill. 2d 19 (1998) (history of relaxing bar against successive petitions)
People v. Tidwell, 236 Ill. 2d 150 (2010) (leave of court required; colorable claim standard used for innocence)
Hodges v. Attorney Gen., 234 Ill. 2d 1 (2009) (frivolous or patently without merit standard at first stage (context))
Schlup v. Delo, 513 U.S. 298 (1995) (no reasonable juror would have convicted under new evidence threshold)
Morgan v. Illinois, 212 Ill. 2d 148 (2004) (conclusive character of new evidence)
Washington v. State, 171 Ill. 2d 475 (1996) (no reasonable juror standard; new evidence must be strong)
People v. Harris, 206 Ill. 2d 293 (2002) (new evidence must be unavailable at trial due to diligence)