People v. Beaman - 229 Ill. 2d 56, 321 Ill. Dec. 778, 890 N.E.2d 500 (2008)

Rule:

When a defendant claims that evidence material to the defendant's guilt or sentence has been withheld, evidence is material if there is a reasonable probability that the result would have been different had it been disclosed. An accused must show the favorable evidence could reasonably be taken to put the whole case in such a different light as to undermine confidence in the verdict. The impact of alternative-suspect evidence on a verdict cannot be determined without viewing the strength of the evidence presented by the accused as well as the evidence presented by the State.

Facts:

The petitioner inmate, Alan Beaman, appeals the dismissal of his postconviction petition. His petition stems from a first-degree murder conviction and sentence of 50 years. The appellate court affirmed his conviction on direct appeal. Petitioner then filed his postconviction petition alleging several violations of his constitutional rights. After petitioner inmate's first-degree murder conviction was affirmed, he sought postconviction relief under the Post-Conviction Hearing Act, 725 Ill. Comp. Stat. Ann. 5/122-1 et seq. (2000) in the trial court. The trial court dismissed the petition and the appellate court affirmed. Petitioner sought further review. On appeal, petitioner asserts several claims, including that the State violated his constitutional right to due process of law by failing to disclose information about a viable alternative suspect in the murder.

Issue:

Did the State violated petitioner’s constitutional right to due process of law by failing to disclose information about a viable alternative suspect in the murder?

Answer:

Yes. The judgments of the trial and appellate courts were reversed, and the matter was remanded to the trial court for a new trial.

Conclusion:

The court held that the trial court barred alternative suspect evidence. The court found that the State admitted withholding evidence which the inmate said established an alternative suspect. This evidence showed a possible alternative suspect because it showed the suspect intentionally avoided a polygraph test, physically abused his girlfriend and was renewing his romantic relationship with the victim, and abused steroids, supporting an inference of violent tendencies, and also, it was owed money by the victim for drugs. This undisclosed evidence and disclosed evidence tending to show the suspect was a viable alternative suspect was not remote or speculative, given the State's tenuous evidence against the inmate. The evidence countered the State's central claim that all other potential suspects had been eliminated. The court held that there was a reasonable probability that the trial's result would have differed had the inmate been able to present the withheld evidence establishing the suspect as an alternative suspect. The State's suppression of the withheld evidence violated the inmate's constitutional right to due process under Brady, and dismissal of the inmate's Brady claim was manifest error.