People v. Griffin
2024 IL 128587
Ill.2024Background
- Shamar Griffin pled guilty in 2011 to first-degree murder in exchange for a 35-year sentence, with additional charges dismissed.
- Years later, Griffin sought to file a successive postconviction petition, alleging actual innocence based on new affidavits and ineffective assistance of counsel.
- The circuit court denied his motion, holding that a guilty plea barred an actual innocence claim; the appellate court reversed, citing People v. Reed.
- Key new evidence included affidavits from witnesses implicating an alternate suspect, Jerrell Butler, and asserting false identifications by State witnesses.
- The appellate court allowed the actual innocence claim and remanded the entire petition, without separate review of the ineffective assistance claim.
- The Illinois Supreme Court granted review to resolve the standard for actual innocence claims following a guilty plea and whether each claim in a successive petition must meet required standards individually.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Standard for leave to file successive postconviction petition based on actual innocence after guilty plea | Griffin: Standard should be same as for trial-convicted petitioners (colorable claim/Robinson standard) | State: A more stringent standard applies for guilty pleas (clear & convincing evidence as in Reed) | The same (Robinson) standard applies at leave-to-file stage regardless of plea or trial; credibility is assessed later |
| Application of new evidence at leave-to-file stage | Griffin: Affidavits are new, material, noncumulative, shift likelihood of conviction | State: Evidence unreliable, contradicted by record, only robust new evidence should suffice | Affidavits taken as true at this stage; colorable claim standard met; court cannot weigh credibility or reliability yet |
| Processing of multiple claims in a successive petition | Griffin: If one claim suffices (actual innocence), all may proceed | State: Each claim must separately satisfy cause and prejudice or actual innocence to move forward | Each claim must independently meet the requisite standard to advance; ineffective assistance claim remanded for standard determination |
| Impact of guilty plea on postconviction innocence claims | Griffin: Reed allows actual innocence claim after guilty plea | State: Guilty plea should bar or strictly limit such claims | Guilty plea does not preclude actual innocence claim, but heightened standard comes into play at evidentiary hearing, not at leave-to-file stage |
Key Cases Cited
- People v. Reed, 2020 IL 124940 (Ill. 2020) (Guilty plea does not bar actual innocence claims; sets clear and convincing standard for third-stage evidentiary hearing)
- People v. Robinson, 2020 IL 123849 (Ill. 2020) (Sets the leave-to-file standard for successive postconviction petitions alleging actual innocence)
- People v. Edwards, 2012 IL 111711 (Ill. 2012) (Affirms requirements for successive postconviction petitions; cause/prejudice or fundamental miscarriage of justice/actual innocence)
- People v. Washington, 171 Ill. 2d 475 (Ill. 1996) (Defines standards for newly discovered evidence claims in postconviction proceedings)
- People v. Pitsonbarger, 205 Ill. 2d 444 (Ill. 2002) (Establishes cause-and-prejudice test application to individual claims in successive petitions)