People v. Reed
2020 IL 124940
Ill.2020Background
- Reed was charged with armed violence and related drug and weapons offenses after fleeing police; officers found a sawed-off shotgun under a bed and a small amount of cocaine in the house; State said shotgun bore Reed’s DNA.
- Reed pleaded guilty to armed violence in exchange for a 15-year sentence; the plea included a Rule 402 factual basis describing flight, drugs, and the shotgun with Reed’s DNA.
- Reed filed a successive post-conviction petition claiming actual innocence, attaching an affidavit from Davie Callaway stating Callaway (not Reed) owned the cocaine and Reed had no knowledge of it.
- The trial court held a third-stage evidentiary hearing, found Callaway not credible, and denied relief; the Fourth District affirmed on the ground that a guilty plea foreclosed an actual-innocence claim.
- The Illinois Supreme Court held that a guilty plea does not categorically bar an actual-innocence claim under the Post-Conviction Hearing Act but affirmed denial of Reed’s petition on the merits.
Issues
| Issue | People’s Argument | Reed’s Argument | Held |
|---|---|---|---|
| Whether a guilty plea bars a freestanding actual-innocence claim under the Act | A knowing, voluntary guilty plea waives nonjurisdictional claims and thus forecloses a freestanding innocence claim | Washington’s due‑process rationale permits innocence claims even after a guilty plea; plea waiver of trial rights shouldn’t preclude relief when new evidence shows innocence | A guilty plea does not categorically bar an actual‑innocence claim; such claims remain cognizable under the Act |
| Standard for actual-innocence claims following a guilty plea | Require a high reliability showing (State urged forensic evidence or federal Schlup-like limits) to protect plea finality | Apply Washington’s new, material, noncumulative evidence standard or compare new evidence to plea record | Guilty-plea claimants must show new, material, noncumulative evidence that clearly and convincingly demonstrates a trial would probably result in acquittal (a stricter standard than Washington for trial convictions) |
| Whether the plea record conclusively rebuts Reed’s new evidence | The plea admission and factual basis (including alleged DNA on the gun) rebut Callaway’s affidavit | The plea admission is not conclusive proof of factual guilt and does not bar consideration of new evidence | The plea record does not automatically rebut an innocence claim; the court must assess new evidence against the plea record and the higher standard applies |
| Whether the trial court erred in denying relief after the evidentiary hearing | Trial court reasonably discredited Callaway (timing, prison contact with Reed) and thus denial was proper | Reed argued the credibility concerns were legally improper because Callaway’s prison proximity was not probative of dishonesty | The Supreme Court found no manifest error in the trial court’s credibility findings and affirmed denial on the merits |
Key Cases Cited
- People v. Washington, 171 Ill. 2d 475 (Ill. 1996) (recognizing freestanding actual-innocence claims under the Post-Conviction Hearing Act on due‑process grounds)
- People v. Cannon, 46 Ill. 2d 319 (Ill. 1970) (statement suggesting guilty plea may preclude later innocence claim; treated as dicta)
- People v. Barker, 83 Ill. 2d 319 (Ill. 1980) (factual-basis requirement for pleas is less stringent than proof at trial)
- Brady v. United States, 397 U.S. 742 (U.S. 1970) (plea bargaining realities; innocent defendants sometimes plead guilty)
- Schlup v. Delo, 513 U.S. 298 (U.S. 1995) (federal gateway standard for actual-innocence claims)
- People v. Schneider, 25 P.3d 755 (Colo. 2001) (en banc) (recognizing heightened standard for actual-innocence claims after guilty pleas)