People v. Woods
961 N.E.2d 466
Ill. App. Ct.2011Background
- Woods was convicted by a jury of first degree murder under a felony murder theory and armed robbery, and sentenced to two concurrent 20-year terms.
- The State presented evidence of a January 17, 2006 Auto Zone robbery in Chicago involving three men; one wore a scarf and had a gun, others wore masks.
- Woods allegedly exited the store carrying a bag and then re-entered after shots; police perimeter formation and subsequent arrest followed.
- Defense opened with conceding armed robbery while arguing Woods did not intend to kill; counsel sought to invoke jury sympathy and possibly jury nullification.
- Woods moved for a new trial claiming ineffective assistance of counsel for conceding guilt; the trial court denied, and Woods appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is counsel's concession of armed robbery per se ineffective assistance? | Woods contends concession equates to admitting felony murder guilt. | Woods argues concession violated Strickland by not testing State's case. | Not per se; Strickland apply and testing occurred; no automatic prejudice. |
| Did counsel's strategy prejudice Woods under Strickland? | Conceding guilt deprived Woods of meaningful adversarial testing. | Counsel advocated a defense strategy and tested the State's case. | No prejudice; overwhelming evidence supported guilt; strategy not deficient. |
| Does felony murder liability depend on foreseeability of police shooting of a cofelon? | Concession plus lack of foreseeability could negate murder liability. | Police misconduct could sever causal chain; Woods should not be liable for Jones's death. | Foreseeability and causal connection were properly addressed; trial strategy permissible, and Woods remained liable under law. |
Key Cases Cited
- People v. Hattery, 109 Ill.2d 449 (1985) (conceding guilt may create prejudice if no adversarial testing)
- United States v. Cronic, 466 U.S. 648 (1984) (presumes prejudice when counsel fails to test State's case in certain contexts)
- People v. Johnson, 128 Ill.2d 253 (1989) (limits per se ineffectiveness from conceded guilt; requires careful Strickland analysis)
- People v. Shatner, 174 Ill.2d 133 (1996) (tests whether Shatner's defense strategy negated meaningful adversarial testing)
- People v. Nieves, 192 Ill.2d 487 (2000) (overwhelming evidence can justify non-deficient performance)
- People v. Ganus, 148 Ill.2d 466 (1992) (defense strategy not automatically deficient when evidence overwhelming)
- People v. Bloomingburg, 346 Ill.App.3d 308 (2004) (defense strategy may be constitutional where evidence is strong)
- People v. Morris, 209 Ill.2d 137 (2004) (jury nullification arguments may be used within limits)
- People v. Lowery, 178 Ill.2d 462 (1997) (felony murder liability for direct and foreseeable consequences)