People v. Jones
360 Ill. Dec. 672
Ill. App. Ct.2012Background
- Jones convicted of first-degree murder in a 1996 bench trial and sentenced to 25 years.
- Direct appeal followed; counsel withdrew; conviction affirmed in 2000 (unpublished).
- Jones filed a pro se postconviction petition in 2001; initial dismissal and remand occurred.
- A postconviction evidentiary hearing with 12 witnesses was held from 2008–2009; issues included alibi witnesses, a deceased co-perpetrator (Dwight Washington), and Brady/innocence claims.
- Attorney conduct and the defense strategy were challenged; the court ultimately denied relief on all postconviction claims.
- The appellate court held the petition timely and rather than moot, but affirmed dismissal after full review.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Timeliness and mootness of postconviction petition | Jones argued Henderson requires mootness; petition timely. | State contends Henderson controls, petition moot after release. | Petition timely and not moot; Henderson rejected (court adopts its own reasoning). |
| Fairness of postconviction hearing and evidentiary rulings | Hearing admitted improper or unreliable evidence against Chambers framework. | Court acted within discretion; no abuse of discretion. | Hearing fair; no manifest error in rulings. |
| Ineffective assistance of counsel at trial | Failure to investigate alibi witnesses and to pursue Washington admissions prejudiced defense. | Counsel's actions were reasonable strategic decisions. | Counsel's performance not deficient; no prejudice established. |
| Admissibility of Washington statements (Chambers v. Mississippi) and recantation testimony | Washington statements could be admitted under trustworthiness criteria to show innocence. | Washington was unavailable for cross-examination; statements unreliable. | Chambers criteria not sufficiently satisfied; statements not admitted; no due process violation. |
| Brady violation claim regarding Pia Easley identification | State suppressed exculpatory or impeachment information from Easley. | Easley’s credibility and timing undermines materiality; testimony corroborated others. | No Brady violation; not material to outcome. |
| Actual innocence / newly discovered evidence | Newly discovered Washington admissions would exonerate Jones. | Evidence not new, material, noncumulative or likely to change outcome. | Not newly discovered; insufficient to overturn conviction. |
Key Cases Cited
- People v. Davis, 39 Ill.2d 325 (1968) (standing to seek postconviction relief despite service of sentence)
- People v. Carrera, 239 Ill.2d 241 (2010) (standing and timing under postconviction statute)
- People v. Henderson, 2011 IL App (1st) 090923 (1st Cir. 2011) (mootness ruling on fully served sentence rejected for appealability)
- People v. Hager, 202 Ill.2d 143 (2002) (limits appellate review to frivolousness if petition timely; mootness not automatic)
- People v. Boclair, 202 Ill.2d 89 (2002) (timeliness of postconviction petitions handled by State; review scope)