People v. Macklin, 125 N.E.3d 1246

On Oct. 2, 2011 Jose Gomez and his nephew Wilfredo Garcia were approached by three men; one (later identified as Macklin) produced a gun, fired once, and Garcia was shot in the right hand. Cash and IDs were taken.
Gomez (English-speaking) and Garcia (Spanish-only) separately identified Macklin in police lineups 10 days after the offense; Gomez said he was 100% sure, Garcia about 70% initially.
Defense moved to suppress the lineup identifications as suggestive (arguing Macklin stood out by wearing a white T‑shirt and braids); the court denied the motion after finding the lineups were not suggestive.
At a 2016 bench trial the court found both victims credible and convicted Macklin of armed robbery with personal discharge of a firearm causing great bodily harm; Macklin did not testify or present evidence.
On appeal Macklin challenged (1) sufficiency of the evidence—arguing the eyewitness IDs were unreliable—and (2) trial counsel’s effectiveness for not calling an expert on eyewitness identification. The appellate court affirmed.

Issue	Plaintiff's Argument (People)	Defendant's Argument (Macklin)	Held
Sufficiency of the evidence: Were the eyewitness identifications reliable enough to sustain conviction?	Victims had adequate opportunity, good lighting, separate and consistent lineup IDs (including Gomez’s 100% certainty), prompt lineups (10 days), so a rational trier of fact could credit IDs.	IDs were unreliable: brief/traumatic viewing (weapon focus, seconds), only generic prior description (three Black men in hoodies/caps), lineup-language problems for Garcia, and possible post‑event embellishment.	Affirmed — applying Biggers factors and deferring to the bench finder, court held the identifications were sufficiently reliable to support conviction.
Ineffective assistance of counsel for not calling an eyewitness-identification expert	Trial counsel vigorously moved to suppress, cross‑examined witnesses, and had strategic reasons to forego an expert; Lerma wasn’t decided yet; in a bench trial an expert likely wouldn’t have changed the outcome.	Counsel was deficient for failing to present expert evidence undermining eyewitness reliability (post‑Lerma recognition of the value of such experts).	Affirmed — counsel’s performance was objectively reasonable and there is no reasonable probability an expert would have altered the bench trial result.

Neil v. Biggers, 409 U.S. 188 (establishing factors for evaluating eyewitness identification reliability)
United States v. Wade, 388 U.S. 218 (discussing pitfalls of stranger identifications and suggestive procedures)
People v. Slim, 127 Ill. 2d 302 (applying Biggers factors in Illinois)
People v. Cunningham, 212 Ill. 2d 274 (appellate duty to carefully examine the record while deferring to factfinder)
People v. Lerma, 2016 IL 118496 (holding expert testimony on eyewitness ID may be admissible and useful in appropriate cases)
People v. Gray, 2017 IL 120958 (standard for sufficiency review and deference to trier of fact)
State v. Henderson, 27 A.3d 872 (N.J. 2011) (critical reassessment of traditional ID reliability factors)
State v. Lawson, 291 P.3d 673 (Or. 2012) (analysis of system and estimator variables affecting lineup reliability)