People v. Williams

Defendant was convicted, after bench trial, of misdemeanor domestic battery and sentenced to 18 months of intensive domestic violence probation. Court abused its discretion in denying Defendant's posttrial motion without first holding an evidentiary hearing at which he could present evidence that the State's witnesses had recanted. There was no physical evidence linking Defendant to the crime, the evidence against him was solely testimonial, and all key witnesses recanted their trial testimony. (CUNNINGHAM and CONNORS, concurring.)