People v. House, 2015 IL App (1st) 110580

Background

In 1993 Antonio House (age 19) was convicted of two counts of first‑degree murder and two counts of aggravated kidnapping for deaths arising from a UVL gang dispute; he admitted acting as a lookout in a handwritten statement and was arrested after being chased and found with a handgun.
Key eyewitnesses at trial were Eunice Clark (testified identifying House) and Barry “Smurf” Williams (prior statements placed House at the scene but he had limited recall at trial); ASA Pandit admitted House’s handwritten statement at trial.
House previously sought Office of Professional Standards (OPS) files on Detectives Kato, Chambers, Perez, and Officer Cronin; the trial court performed an in‑camera review primarily focused on Detective Kato and declined broader disclosure; appellate litigation followed and some review occurred previously.
House filed a postconviction petition alleging (1) actual innocence based on Clark’s 2001 recantation affidavit, (2) newly discovered evidence and pattern of police misconduct (including use of rival gang member Lloyd to intimidate him), (3) denial of access to OPS files, (4) ineffective assistance of trial and appellate counsel, and (5) that the mandatory natural‑life sentence for multiple homicides is unconstitutional as applied.
The trial court dismissed the postconviction petition at the second stage; this appeal affirmed that dismissal in part but vacated House’s mandatory natural‑life sentence and remanded for resentencing.

Issues

Issue	Plaintiff's Argument (People)	Defendant's Argument (House)	Held
1) Actual innocence based on Clark’s recantation	Recantation is unreliable and not sufficiently conclusive to overcome trial evidence	Clark’s 2001 affidavit recants trial ID and supports actual innocence/newly discovered evidence	Dismissal affirmed — recantation deemed unreliable, not newly discovered/conclusive enough to probably change outcome
2) Newly discovered evidence / police misconduct (pattern by Det. Kato; Lloyd used to intimidate)	Prior OPS matters and other cases are remote or involve different misconduct; res judicata bars relitigation	OPS records and other affidavits show pattern and corroborate intimidation at Area 4, entitling relief or discovery	Dismissal affirmed — evidence not newly discovered or sufficiently similar; res judicata and lack of materiality; Dunbar affidavit not persuasive
3) Discovery/OPS files & counsel effectiveness for failing to obtain them	Trial court conducted in‑camera review as ordered; requests speculative and lacked good cause	Counsel failed to secure/review all OPS files (Kato, Chambers, Perez, Cronin); prejudice resulted	Dismissal affirmed — record incomplete; no good cause for broader discovery; no showing of Strickland prejudice
4) Mandatory natural‑life sentence (multiple victims) constitutionality	Statute constitutional; applies to adults 17+; sentencing scheme valid	Mandatory life without parole for multi‑murder offenders is disproportionate as applied to a 19‑year‑old lookout and denies consideration of mitigating youth-related factors	Sentence vacated and remanded for new sentencing — the statute, as applied to House, violated Illinois proportionate‑penalties clause (new sentencing hearing ordered)

Key Cases Cited

Strickland v. Washington, 466 U.S. 668 (ineffective assistance two‑prong test)
Apprendi v. New Jersey, 530 U.S. 466 (sentence and fact‑finding principles cited in sentencing claims)
Roper v. Simmons, 543 U.S. 551 (juvenile death‑penalty prohibition; youth mitigation principles)
Graham v. Florida, 560 U.S. 48 (life‑without‑parole for nonhomicide juveniles; youth as mitigating)
Miller v. Alabama, 567 U.S. 460 (mandatory life without parole for juvenile homicide unconstitutional as applied — need to consider youth)
People v. Washington, 171 Ill. 2d 475 (standards for newly discovered evidence/actual innocence)
People v. Miller, 202 Ill. 2d 328 (Illinois analysis of multiple‑murder mandatory life and proportionality)