People v. Tyler

Defendant, age 17 and with no prior record at time of offense, was tried as an adult and convicted of first-degree murder after jury trial in 1995. Only evidence at trail implicating Defendant in the murder was testimony of witness who testified she saw Defendant run through an alley carrying a gun shortly after shooting, and Defendant's confession that he acted as a lookout for the shooter. Defendant testified at trial that a detective physically beat him into giving false confession. Reversed and remanded in part for 3rd-stage evidentiary hearing on Defendant's claim of coerced confession. Defendant is entitled to have evidence of systemic police misconduct considered by trial court at evidentiary hearing, as evidence was sufficient to relax requirements of res judicata and evidence made a substantial showing of a constitutional violation. Evidence of systemic police misconduct is new, material, noncumulative, and is so conclusive it could reasonably change the result on retrial, as evidence is sufficient to support Defendant's claim of actual innocence. (REYES and McBRIDE, concurring.)