Smith v. Brookhart

Federal 7th Circuit Court
Criminal Court
Habeas Corpus
Citation
Case Number: 
Nos. 20-1588 & 20-1666 Cons.
Decision Date: 
April 29, 2021
Federal District: 
N.D. Ill., E. Div.
Holding: 
Reversed and remanded

Dist. Ct. erred in denying defendant's habeas petition that challenged his murder conviction on grounds that trial evidence failed to support his conviction beyond reasonable doubt. Confession by co-defendant that implicated defendant in murder contained inconsistencies, and no physical evidence linked defendant to murder, while record contained evidence linking three other individuals to charged murder, that included corroborated confessions from said individuals that contained facts that were not known by general public. As such, record established as objective matter that no rational trier of fact could have found defendant guilty beyond reasonable doubt. Also, state court improperly precluded defendant from introducing evidence of victim's cocaine dealing, where said evidence established motive for said three individuals to rob victim prior to instant shooting, while defendant and others charged with instant murder did not have such motive.