People v. Fields
2011 IL App (1st) 100169
Ill. App. Ct.2011Background
- 1985 charges against Fields and codefendants for 1984 murders; bench trial led to murder convictions and death sentences; supreme court affirmed convictions in 1990; 1992 amended postconviction petition alleging bribery by Judge Maloney; 1993 Maloney was convicted under RICO and related theories; 1996 retrial order granted and Hawkins and defendant obtained new trial; 2009 bench trial resulted in not guilty verdict for Fields; 2009 petition for certificate of innocence under 2-702 granted by court; appellate reversal on mootness and misapplication of actual innocence standard and remand to determine innocence under 2-702 with proper evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the certificate of innocence was properly granted under 2-702. | State argues the court equated not guilty with actual innocence. | Fields argues the court followed correct standard by considering Langston testimony and petition evidence. | Reversed and remanded for correct 2-702 analysis. |
Key Cases Cited
- People v. Hawkins, 181 Ill. 2d 41 (Ill. 1998) (not guilty finding and innocence standards discussed in postconviction context)
- People v. Fields, 135 Ill. 2d 18 (Ill. 1990) (direct review; prior Bribery/recusal context; standard of review cited)
- United States v. Maloney, 71 F.3d 645 (7th Cir. 1995) (en banc; bribery scheme and trial-fixing evidence cited in postconviction history)
- People v. Klepper, 234 Ill. 2d 337 (Ill. 2009) (law-of-the-case and appellate-remand principles acknowledged)