People v. Fields
2020 IL App (1st) 151735
Ill. App. Ct.2020Background
- In 1997 Leon Fields was convicted of first-degree murder and attempted murder for a Madison Street shooting; he received consecutive terms totaling 80 years. Two State eyewitnesses (Deron James and Curtis Hood) identified him; an other-crimes witness (Michael Welch) testified defendant had shot him in an unrelated incident.
- At trial Curtis Hood signed a pretrial statement recanting his ID but then recanted that statement at trial; defense presented an alibi witness and defense investigators.
- Fields filed successive postconviction petitions asserting actual innocence based on new affidavits from two witnesses: Renee Fitzgerald (attached to the first successive petition) and Crystal Johnson (attached to a later petition). Both averred they saw the shooters and that Fields was not one of them; Fitzgerald also alleged police intimidation caused a prior false identification and said she had moved out of town.
- The trial court dismissed one successive petition at the second stage and denied leave to file the later petition containing Johnson’s affidavit; Fields appealed, and the appeals were consolidated.
- The appellate court evaluated whether the affidavits were (1) newly discovered, (2) material and noncumulative, and (3) of such conclusive character that they would probably change the result on retrial — i.e., whether a third-stage evidentiary hearing is warranted.
Issues
| Issue | Plaintiff's Argument (People) | Defendant's Argument (Fields) | Held |
|---|---|---|---|
| Whether Fitzgerald’s and Johnson’s affidavits are newly discovered | Not newly discovered as defense knew Fitzgerald as a possible witness pretrial; affidavits shouldn’t overcome the record | Affidavits are newly discovered because Fitzgerald moved/was intimidated and thus unavailable; Johnson’s affidavit also newly discovered | Court: Statements are newly discovered (Fitzgerald’s move/intimidation rendered her unavailable; State conceded Johnson was newly discovered) |
| Whether the affidavits are material and noncumulative | Not material: witnesses didn’t clearly observe the shooting or identify Fields; largely cumulative or impeaching | Material and noncumulative: they provide eyewitness exculpation not presented at trial (two witnesses saying Fields wasn’t a shooter) | Court: Both affidavits are material and noncumulative |
| Whether the new evidence is of a conclusive character (probability to change outcome) | Not conclusive; State’s trial evidence was overwhelming; discrepancies (e.g., five vs. four shooters) undermine affidavits; credibility issues | Combined with prior alibi and recantations, the affidavits likely would change the result or at least warrant credibility testing at an evidentiary hearing | Court: Petitioner made a substantial showing that the new evidence could probably change the result; credibility contests require a third-stage hearing |
| Whether leave to file the successive petition should be denied | Trial court denied leave for Johnson petition as the affidavit alone was not conclusive | Leave should be granted; petition presents a colorable actual-innocence claim | Court: Reversed trial court; remanded both petitions for a third-stage evidentiary hearing |
Key Cases Cited
- People v. Pitsonbarger, 205 Ill. 2d 444 (defines cause-and-prejudice standard for successive petitions)
- People v. Sanders, 2016 IL 118123 (standards for second-stage dismissal and actual-innocence gateway)
- People v. Coleman, 2013 IL 113307 (elements of newly discovered evidence and conclusive-character inquiry)
- People v. Allen, 2015 IL 113135 (actual-innocence evidence standards)
- People v. Stoecker, 2014 IL 115756 (clarifies materiality requirement)
- People v. Robinson, 2020 IL 123849 (standard for denial of leave to file successive petition based on actual innocence)
- People v. Ortiz, 235 Ill. 2d 319 (witness unavailability due to moving can make evidence newly discovered)
- People v. White, 2014 IL App (1st) 130007 (threats/intimidation can render a witness unavailable pretrial)
- People v. Harper, 2013 IL App (1st) 102181 (recantation where intimidation prevented truthful testimony supports newly discovered finding)
- People v. Ward, 2011 IL 108690 (treatment of acquittal when used as other-crimes evidence)
- People v. Buffer, 2019 IL 122327 (appellate court may act in interests of judicial economy)
- People v. Edwards, 2012 IL 11171 (discussion that "evidence in support" of innocence must be newly discovered)