People v. Dumas

To obtain a certificate of innocence per Section 2-702 of Code of Criminal Procedure, a defendant must show by a preponderance of the evidence that he is actually innocent and that he did not act in a way that brought about his conviction; a reversal for failure to prove guilt beyond a reasonable doubt will not suffice. Court properly denied Defendant's request for certificate of innocence, as record shows that Defendant took multiple steps to arrange a drug sale, which ultimately led to his arrest and conviction, and thus he voluntarily caused or brought about his own conviction. (ZENOFF and HUDSON, concurring.)