People v. Fields
355 Ill. Dec. 429
Ill. App. Ct.2011Background
- In 1985 Fields and co-defendants Hawkins and Carter were charged with April 1984 murders; bench trial; Fields and Hawkins were convicted of murder and sentenced to death; the Illinois Supreme Court affirmed the convictions in 1990.
- In 1992 Fields filed an amended postconviction petition alleging bias/bribery by Judge Maloney based on a 1991 federal grand jury indictment of Maloney.
- In 1993 Maloney was found guilty in federal court of RICO violations, extortion conspiracy and obstruction of justice; the state showed he took a bribe and later convicted Fields after perceiving FBI attention.
- In 1996 the trial court vacated Fields’ conviction and granted a new trial; the Illinois Supreme Court affirmed on direct appeal.
- On remand, the court denied the State’s bribery evidence motions; there were subsequent interlocutory appeals affirming denial of bribery evidence due diligence.
- In 2009 a bench trial resulted in Fields being found not guilty; the court noted there was no unimpeached witness identifying Fields as a shooter.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether 2-702 actual innocence requires a distinction from retrial acquittal | State: statute requires a separate actual innocence showing | Fields: the court properly applied the standard as to innocence | Court held 2-702 requires distinction; remand for proper consideration of innocence evidence |
| Whether the appeal is moot | State: relief could affect related claims despite payment | Fields: moot because compensation settled the issue | Appeal not moot; proceed on merits per law-of-the-case |
| Whether the circuit court erred by not considering Langston affidavit and related materials | State: need not consider Langston materials | Fields: those materials are essential to prove innocence | Court erred; remand to consider attached materials in light of 2-702 |
Key Cases Cited
- People v. Fields, 135 Ill.2d 18 (1990) (direct appeal on initial murder conviction)
- People v. Hawkins, 181 Ill.2d 41 (1998) (supreme court direct appeal following remand for new trial)
- People v. Hawkins, 326 Ill. App.3d 992 (2001) (interlocutory appeals on bribery evidence due diligence)
- People v. Fields, 357 Ill. App.3d 780 (2005) (interlocutory appeal upholding denial of bribery evidence)
- United States v. Maloney, 71 F.3d 645 (7th Cir.1995) (Judge Maloney bribery scheme; en banc)