People v. Myles
175 N.E.3d 756
Ill. App. Ct.2020Background
- Defendant Eddie Myles was convicted of robbing a 66‑year‑old shopper (Maryanne Koll) in a Jewel grocery store; two eyewitnesses (Koll and Sheila LaRoche) identified him and the jury found him guilty.
- Myles testified the contact was accidental, that he carried an art portfolio and picked up his wife’s medication; he denied taking Koll’s money.
- After conviction and sentencing (20 years, Class X), Myles filed a postconviction petition alleging the State failed to disclose that Koll had pending federal fraud and bribery charges (she was later convicted).
- Trial counsel submitted an affidavit saying the prosecution did not disclose Koll’s charges and that, had he known, he would have used that information to impeach her.
- The circuit court dismissed the petition at the second stage, concluding the pending federal charges were immaterial/improper for impeachment and would not have changed the outcome.
- The appellate court reversed and remanded for an evidentiary hearing, holding Myles made a substantial showing that counsel was deficient for failing to investigate and that the pending charges could have shown bias/leniency motive and prejudiced the verdict.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Myles is entitled to an evidentiary hearing on his claim that trial counsel was ineffective for failing to discover and use Koll’s pending federal fraud/bribery charges to impeach her credibility | Impeachment by mere arrests/charges is impermissible; the pending federal case was not material and would not have changed the outcome given independent eyewitness testimony | Counsel failed to investigate Koll’s background; pending charges could show motive to curry favor or obtain leniency and would have been used to impeach, likely affecting the closely contested credibility determination | Reversed and remanded for an evidentiary hearing: pending charges could be proper impeachment to show bias/interest/leniency motive; counsel’s failure to investigate and impeach was deficient and prejudicial at second‑stage review |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (establishes deficient performance and prejudice test for ineffective assistance)
- People v. Triplett, 108 Ill. 2d 463 (pending charges or custody may be inquired into to show motivation/bias)
- People v. Pendleton, 223 Ill. 2d 458 (postconviction Act three‑stage framework and second‑stage standard)
- People v. Steidl, 177 Ill. 2d 239 (value of investigation depends on the probative value to the case; failure to investigate can be ineffective assistance)
- People v. Kellas, 72 Ill. App. 3d 445 (unrelated pending charges are proper subjects for cross‑examination to show bias)
- People v. Makiel, 358 Ill. App. 3d 102 (questions about prosecution’s leverage over a witness implicate credibility and may require an evidentiary hearing)