People v. Wilson
2025 IL App (1st) 230027
Ill. App. Ct.2025Background
- Rayvonne Wilson pleaded guilty to first degree murder in 2010, receiving a life sentence to avoid the death penalty, after being accused of shooting his cousin Reginald Bradley in a family dispute in 2004.
- The original factual basis for the plea was based primarily on Reginald's deposition before his death and a stipulation of corroboration by his uncle Harry Wilson, both indicating Rayvonne was the aggressor.
- Years later, Rayvonne sought postconviction relief based on affidavits—including from Harry—asserting Reginald was the aggressor, pulling a gun on Rayvonne before the struggle and shooting.
- The trial court denied Rayvonne leave to file a successive postconviction petition, ruling the affidavits were not newly discovered evidence because Rayvonne could have presented them earlier.
- On appeal, the question was whether these affidavits qualified as newly discovered evidence supporting a colorable claim of actual innocence warranting further proceedings.
- The appellate court reversed, focusing especially on Harry's recantation, and remanded for a second-stage postconviction hearing.
Issues
| Issue | Wilson's Argument | State's Argument | Held |
|---|---|---|---|
| Whether Wilson can raise actual innocence after guilty plea | Yes; new evidence shows he acted in self-defense and was actually innocent | No; guilty plea bars claim and defense should have been raised earlier | Guilty plea does not bar actual innocence claims with new, compelling evidence |
| Whether affidavits qualify as newly discovered evidence | Affidavits were not available prior and due diligence could not secure them | Affidavits not new—Wilson knew facts and witnesses before plea | Harry’s affidavit is newly discovered; due diligence standard applied reasonably |
| Whether new evidence is material and potentially exculpatory | Affidavits show Reginald was aggressor, supporting justification/self-defense | Evidence not conclusive; would not likely change result, barbershop witness easily located | At leave-to-file stage, Harry's recantation alone could lead to acquittal if believed |
| Application of forfeiture to actual innocence claims post-guilty plea | Forfeiture is inapposite; actual innocence claims are unique | Forfeiture applies if not raised earlier | No forfeiture; actual innocence claims are not forfeited by guilty plea or failure to raise earlier |
Key Cases Cited
- People v. Robinson, 2020 IL 123849 (actual innocence claims must show evidence that is newly discovered, material, noncumulative, and potentially conclusive)
- People v. Reed, 2020 IL 124940 (actual innocence claim survives guilty plea; higher burden applies at later stages)
- People v. Edwards, 2012 IL 111711 (new evidence is 'newly discovered' if not available due to witness's unwillingness to testify before)
- People v. Ortiz, 235 Ill. 2d 319 (eyewitness accounts not previously known to defendant can be newly discovered even if present at the scene)
- People v. Griffin, 2024 IL 128587 (standard for actual innocence at leave-to-file stage is same for trial/guilty plea—whether new evidence, if believed, could lead to acquittal)