People v. Reed
2019 IL App (4th) 170090
Ill. App. Ct.2019Background
- In April 2015, Demario D. Reed entered a negotiated guilty plea to armed violence (possession of cocaine while armed with a shotgun) and was sentenced to 15 years imprisonment; plea colloquy included full admonitions and waiver of jury trial.
- Reed later filed a successive postconviction petition claiming actual innocence of armed violence based on a codefendant Davie Callaway’s affidavit/testimony that Callaway alone possessed the cocaine.
- The State moved to dismiss, arguing waiver; the trial court allowed the petition to advance and held an evidentiary hearing on the newly offered evidence.
- At the January 2017 hearing, the court found Callaway’s testimony qualified as new evidence but found him not credible and denied relief, concluding Reed had not established a colorable claim of actual innocence.
- Reed appealed, arguing his newly discovered evidence proved actual innocence despite his prior valid guilty plea; the appellate court considered whether such a claim may be entertained after a knowing, voluntary plea.
Issues
| Issue | Plaintiff's Argument (People) | Defendant's Argument (Reed) | Held |
|---|---|---|---|
| Whether a freestanding claim of actual innocence may be raised in postconviction proceedings after a valid guilty plea | A valid, knowing, voluntary guilty plea waives nonjurisdictional claims including actual innocence; estoppel and invited-error doctrines bar relief | A defendant may bring a freestanding actual innocence claim based on newly discovered evidence despite a prior valid plea | Held: No. A valid guilty plea bars consideration of a freestanding actual-innocence claim; Reed remains bound by his plea |
| Whether Callaway’s affidavit/testimony constituted sufficient newly discovered evidence to obtain relief | Evidence must overcome waiver/plea-bar; State challenged credibility and relevance | Reed argued Callaway’s affidavit was new evidence proving Reed’s innocence and merited relief | Held: Court found Callaway not credible; even if new, the plea-bar doctrine precludes relief |
| Whether Washington standard for newly discovered evidence applies after a guilty plea | The Washington standard (new, material, noncumulative, and conclusive) governs postconviction actual-innocence claims | Reed relied on newly discovered evidence to satisfy standard | Held: Washington applies to postconviction claims after trial but is inapplicable to guilty-plea cases because pleas dispense with proof; thus, the plea-bar remains controlling |
Key Cases Cited
- People v. Pendleton, 223 Ill. 2d 458 (Illinois Supreme Court) (discusses limits on postconviction claims)
- People v. Cannon, 46 Ill. 2d 319 (Illinois Supreme Court) (statement that postconviction actual-innocence claims cannot be entertained after a valid guilty plea)
- People v. Barnslater, 373 Ill. App. 3d 512 (Illinois Appellate Court) (discusses plea-bar to actual-innocence claims; dictum cited)
- People v. Washington, 171 Ill. 2d 475 (Illinois Supreme Court) (holds newly discovered evidence claims of actual innocence cognizable postconviction when based on trial conviction)
- Hill v. Cowan, 202 Ill. 2d 151 (Illinois Supreme Court) (explains that a guilty plea waives right to proof beyond a reasonable doubt)
- Exelon Corp. v. Department of Revenue, 234 Ill. 2d 266 (Illinois Supreme Court) (discusses persuasive force of obiter dictum from court of last resort)