People v. Harris, 2025 IL 130351

Ralph Harris was convicted in three separate cases involving murder, attempted (armed) robbery, and aggravated criminal sexual assault, and his convictions were originally upheld on direct appeal.
Harris filed postconviction petitions under the Illinois Post-Conviction Hearing Act (725 ILCS 5/122-1 et seq.), alleging his confessions were coerced by police, citing new evidence of Area 2 police torture.
After a combined third-stage evidentiary hearing, the circuit court denied Harris’s petitions, finding his new evidence insufficient to prove coercion had impacted his confessions.
On appeal (Harris I), the appellate court found errors in how the circuit court handled the suppression issue and remanded for a new suppression hearing before a new judge, but did not expressly vacate the convictions or order new trials.
On remand, the new circuit court judge found the confessions voluntary but still vacated the convictions and granted new trials, suggesting new evidence might affect a jury’s consideration.
The State appealed the order granting new trials, but the appellate court dismissed the appeal for lack of jurisdiction, reasoning the order was not final or appealable by the State. The State sought review in the Illinois Supreme Court.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Jurisdiction: Was the circuit court's order granting new trials a final and appealable postconviction order?	State: Yes, it's a final order under the Act, appealable by the State.	Harris: No, Harris I ended the postconviction case, so this was a new pretrial order, not appealable.	The order was a final, appealable postconviction order; appellate court has jurisdiction.
Did Harris I's mandate vacate the convictions and direct new trials?	State: No, Harris I just called for a new suppression hearing, not vacatur/new trials.	Harris: Yes, Harris I necessarily granted postconviction relief, vacating convictions.	Harris I did not vacate convictions/new trials; mandate was for a new suppression hearing only.
Proper procedural structure for postconviction coerced confession claims under Illinois law	State: Postconviction has only three stages, no new suppression hearing outside the process.	Harris: Appellate court can remand for a new suppression hearing as additional process.	Only three stages exist; any additional suppression hearing should fit within the Act's stages.
Whether the State could appeal the circuit court’s grant of new trials from postconviction relief	State: Precedent allows State appeals from final postconviction orders granting new trials.	Harris: Appeal only proper from interlocutory orders under Rule 604(a), which this was not.	State can appeal a final postconviction order granting new trials; appeal proper here.

People v. Joyce, 1 Ill. 2d 225 (Ill. 1953) (holding State can appeal from a postconviction order granting a new trial)
People v. Scott, 194 Ill. 2d 268 (Ill. 2000) (affirming State's right to appeal postconviction relief granting a new sentencing hearing)
People v. Coleman, 2013 IL 113307 (Ill. 2013) (defining the burden of proof at third-stage postconviction hearings and appellate review standard)
People v. Patterson, 192 Ill. 2d 93 (Ill. 2000) (addressing the standard for new evidence supporting coerced confession claims)
People v. Wrice, 2012 IL 111860 (Ill. 2012) (discussing harmless error analysis for use of coerced confessions at trial)