People v. Coleman

Illinois Supreme Court
Criminal Court
Citation
Case Number: 
2013 IL 113307
Decision Date: 
October 3, 2013
District: 
3d Dist.
Division/County: 
Peoria Co.
Justice: 
THEIS
Holding: 
Circuit court and appellate court reversed; remanded.
Where a defendant makes a claim of trial error, and an actual-innocence claim in a successive postconviction petition, the claim of trial error must meet the cause-and-prejudice standard, and the actual- innocence claim must meet the substantive standard of compelling evidence, as set forth in the Washington decision. To succeed on an actual-innocence claim, the defendant must present new, material, noncumulative evidence that is so conclusive it would probably change the result on retrial. (KILBRIDE, FREEMAN, THOMAS, GARMAN, KARMEIER, and BURKE, concurring).