The Illinois Appellate Court has affirmed the denial of Martin Hill’s bid for a new trial based on claims of actual innocence, ruling that the new evidence presented was not conclusive enough to likely change the outcome if the case were retried. The decision hinged on the circuit court’s assessment of witness credibility during a third-stage evidentiary hearing, where the judge found the defense witnesses unconvincing compared to the testimony given at the original 1998 trial.
Hill, who was 15 years old when he was convicted for a 1994 shooting that resulted in two murders, has been fighting his conviction for years. While his life sentence was previously vacated and remanded for resentencing, the current appeal focused solely on his claim that new evidence proves his innocence.
The Original Trial: A Case Built on Eyewitness Accounts
The 1994 incident involved the shooting of three people in a parked car, killing two occupants. Hill and co-defendant McKenzie Ranson were tried together, though by separate juries. Tommy Wilson, the driver, was tried separately. Hill was convicted of two counts of murder and one count of attempted murder.
The State’s case heavily relied on the testimony of two 17-year-olds, LaQuita Ratliff and Cassandra Crudup. Ratliff provided a highly detailed account, specifying the movements of the maroon Chevy carrying Hill, Ranson, and Wilson, and describing sparks coming from the passenger seats as shots were fired. Crudup largely corroborated this version.
The sole surviving victim, Jake Vincent, testified at trial that he heard 10 to 15 shots from behind the car, causing him to duck, and he never saw the shooters, believing they were on foot. In contrast to the eyewitnesses, Hill initially told detectives that the shooters were in Wilson’s car.
The Postconviction Challenge: Recanting Witnesses and New Claims
Hill’s postconviction efforts brought forward three key witnesses whose testimony sharply contradicted the trial narrative:
1. Jake Vincent: The surviving victim, who previously testified he didn’t see the shooters, later provided an affidavit claiming he *did* see the gunmen—Tyreese Tart and Byron Logan—approaching on foot. Vincent explained his initial trial testimony by claiming he was threatened by Logan and Tart after the incident, warning him to stay silent.
2. Dwond Donahue: Serving a long sentence for murder, Donahue claimed he witnessed the shooting from his car on a nearby street. He identified two men walking from a vacant lot, “Terrell/T-bone” and “Big Byron,” as the shooters, emphasizing they were on foot. He stated definitively that Hill was not involved.
3. LaQuita Ratliff: Perhaps the most significant development, Ratliff, now a registered nurse living out of state, recanted her trial testimony. She claimed she hadn’t witnessed the shooting at all but only repeated a story told to her by Crudup and a roommate. She asserted she was pressured by the prosecutor to stick to the police reports.
The Circuit Court’s Findings: Deference to Trial Credibility
The case advanced to a third-stage evidentiary hearing where the circuit court heard live testimony from these three witnesses. The court ultimately rejected their new evidence, concluding it was not of such a “conclusive character” that it would probably change the result on retrial.
The judge gave significant weight to the original trial record. The court specifically noted Ratliff’s trial testimony as “incredibly detailed,” involving diagrams and precise recollections of car movements, which strongly undercut her later claim that she was merely repeating secondhand information. The judge also found Vincent’s shifting accounts—from testifying he saw nothing, to naming alleged shooters, to contradicting himself again—to be unreliable. Donahue’s testimony was dismissed as “incredible and unworthy,” especially given his 20-year delay in coming forward.
Appellate Court Affirms: Deference to Fact-Finder
On appeal, the Appellate Court acknowledged the high standard required for new evidence to warrant a retrial: it must be conclusive enough to probably change the result. The court stressed that when a circuit court holds an evidentiary hearing, it is uniquely positioned to judge witness credibility.
Justice Gamrath, writing for the majority, stated that the appellate review is limited to determining if the circuit court’s decision was “manifestly erroneous”—meaning clear, obvious, and indisputable error.
The majority found the circuit court’s rejection of the new testimony entirely reasonable. Ratliff’s previous detailed, first-person testimony, corroborated by Crudup, stood in stark contrast to her new, uncorroborated claim of ignorance. Furthermore, the original prosecutor testified that Ratliff never indicated she hadn’t witnessed the event firsthand.
Regarding Vincent and Donahue, the court noted their decades-long silence and the inherent unreliability typically associated with recantation evidence. The court concluded that the inconsistencies within the new statements, combined with the high credibility of the original trial testimony, meant Hill had not met his burden.
Dissent Argues for Re-evaluation
Justice Hyman issued a strong dissent, arguing that the majority placed too much emphasis on the original trial record and afforded excessive deference to the circuit court’s disbelief of the new witnesses.
The dissent highlighted that postconviction review exists precisely because trial reliability can erode over time, especially when the State’s own Conviction Integrity Unit (CIU) previously signaled institutional doubt by investigating the case. Justice Hyman contended that Ratliff’s current status as an educated professional, far removed from gang life, lent credibility to her recantation, suggesting she was finally free from the pressures that led to her initial testimony.
Furthermore, the dissent emphasized the cumulative effect of the new evidence: the fact that two witnesses (Vincent and Donahue) stated the shooters were on foot, which contradicts the trial theory that shots were fired from a moving car, seriously undermines the original conviction. The dissent also pointed out a lack of physical evidence tying Hill to the crime, noting that recovered bullets did not match the caliber Hill allegedly possessed, according to his own police statement.
Ultimately, the majority found no manifest error in the circuit court’s decision to prioritize the trial testimony over the recantations and new claims, affirming the denial of the postconviction petition.