Solomon Monroe v. Randy J. Davis
2013 U.S. App. LEXIS 6770
7th Cir.2013Background
- Monroe was convicted of first-degree murder on an accountability theory in Illinois, sentenced to 40 years.
- He petitioned for federal habeas relief challenging a Fourth Amendment arrest, ineffective-assistance, and sufficiency of the evidence claims.
- Police arrested Monroe at his home after investigations tied to the Stalker killing; his statements were made post-arrest.
- Jackson, a key witness, described roles of Monroe and others in a drug operation and the assault.
- Monroe moved to suppress post-arrest statements and sought suppression of arrest; state courts denied relief; federal court denied habeas relief.
- District court found Stone v. Powell barred merits review of the Fourth Amendment claim; affirmed against Monroe on other claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Monroe was arrested with probable cause | Monroe argues lack of probable cause at arrest | State argues full and fair state-court hearing precludes merits | Stone bar applies; no merits review on Fourth Amendment |
| Sufficiency of evidence for accountability theory | Evidence does not show a common design to beat Stalker | Evidence supports common design and Monroe's aiding conduct | Evidence sufficient; Illinois appellate standard applied reasonably |
| Ineffective assistance for not calling Estavia witnesses | Estavias would have attacked police conduct and supported suppression/credibility | Strategic decision; no prejudice shown | No unreasonable application of Strickland; no prejudice established |
Key Cases Cited
- Stone v. Powell, 428 U.S. 465 (U.S. 1976) (restrains federal review of state-court Fourth Amendment claims when full and fair hearing occurred)
- Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (measures sufficiency of evidence under Jackson standard on collateral review)
- Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (establishes framework for evaluating ineffective-assistance claims)
- Beck v. Ohio, 379 U.S. 89 (U.S. 1964) (probable cause standard for Fourth Amendment)
- People v. Kidd, 675 N.E.2d 910 (Ill. 1996) (Illinois precept on probable cause standard)
- People v. Shaw, 713 N.E.2d 1161 (Ill. 1998) (common-design theory and accountability)