People v. Morgan

Summary

The Illinois Supreme Court affirmed the denial of Samuel Morgan’s successive postconviction petition asserting actual innocence based primarily on an eyewitness’s recantation. The court held that the recanted testimony was not sufficiently conclusive to warrant a new trial and that the circuit court’s credibility determinations were not manifestly erroneous. The court also rejected related due process and section 2-1401 arguments.

Holdings

1. The statutory bar on successive postconviction petitions may be relaxed when fundamental fairness requires it, and a defendant must establish cause and prejudice for each claim; the State conceded that Morgan satisfied this threshold for an evidentiary hearing.
2. A claim of actual innocence based on newly discovered evidence requires evidence that was unavailable at trial and could not have been discovered earlier through diligence, is material and noncumulative, and is so conclusive that it would probably change the result on retrial. Morgan's evidence did not satisfy the conclusive-character requirement.
3. The circuit court did not manifestly err in rejecting Prater's recantation, the coercion testimony, and the related evidence attacking eyewitness Gregson's credibility.
4. The circuit court did not abuse its discretion by excluding evidence concerning police conduct in an unrelated case because the circumstances were materially different from Prater's allegations.
5. Morgan was not entitled to relief under either due process or section 2-1401 because both arguments depended on accepting Prater's new testimony as truthful, and the circuit court properly rejected that testimony.

Questions Presented

1. Whether Morgan's successive postconviction petition could be considered under the fundamental-fairness exception to the statutory bar on successive petitions.
2. Whether Prater's recanted testimony constituted newly discovered evidence of such conclusive character that it would probably change the result on retrial and therefore supported actual-innocence relief.
3. Whether the circuit court manifestly erred in rejecting Prater's recantation and related testimony as not credible.
4. Whether the circuit court abused its discretion by excluding evidence concerning alleged police coercion of a defendant in an unrelated case.
5. Whether Morgan was entitled to relief under the due process clause of the Illinois Constitution or section 2-1401 of the Code of Civil Procedure.

Disposition

affirmed