People v. Manning
241 Ill. 2d 319
| Ill. | 2011Background
- Defendant Arthur Manning was convicted by jury in Du Page County of possession with intent to deliver cocaine and possession of cocaine, with concurrent terms of 11 and 3 years.
- Police undercover sting and subsequent search at 37 Sunset Court in Bensenville yielded cocaine, heroin, a scale, and IDs linking Manning to that address.
- During voir dire, defense highlighted Manning’s sex-offender status and residence to probe potential juror bias; juror A.C. stated he could not be fair.
- Trial testimony included police undercover operation, defendant’s statements claiming Sunset Court residence, and discovery of heroin and cocaine in multiple locations.
- Appellate court affirmed; Manning pursued a petition for leave to appeal arguing ineffective assistance for failing to strike A.C. and requested adherence to Metcalfe; this court granted review.
- This court ultimately declined to overrule Metcalfe and affirmed the appellate court’s judgment, holding counsel’s conduct during voir dire was not deficient.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether counsel was ineffective for not challenging A.C. for cause or with a peremptory strike. | Manning | Counsel failed to strike a biased juror | Not deficient; strategy reasonable |
| Whether Metcalfe should be overruled or prejudice presumed for biased juror seating. | Manning | Should overrule Metcalfe; bias presumed | Metcalfe not overruled; prejudice not presumed in this case |
| Whether the presence of a biased juror rendered the trial unreliable, warranting reversal. | Manning | Trial still fair; no prejudice shown | Trial not unreliable; affirm |
Key Cases Cited
- People v. Metcalfe, 202 Ill.2d 544 (2002) (Strickland analysis; bias during voir dire, no automatic reversal)
- Strickland v. Washington, 466 U.S. 668 (1984) (two-prong standard for ineffective assistance of counsel)
- People v. Albanese, 104 Ill.2d 504 (1984) (adopts Strickland standard in Illinois)
- People v. Glasper, 234 Ill.2d 324 (2006) (bias on juror and prejudice analysis in Strickland framework)
- United States v. Martinez-Salazar, 528 U.S. 304 (2000) (bias on jury renders trial unreliable; prejudice prong considerations)