THE PEOPLE OF THE STATE OF ILLINOIS v. MICHAEL McCOY (2026)

This case concerns how the evidence should be evaluated when a defendant's postconviction petition has made it to the third stage. Michael McCoy was convicted of murder and armed robbery of a Chicago liquor store owner in 1986. His successive postconviction petition made it to the third stage, where the trial court acts as factfinder and evaluates credibility. He presented testimony from a codefendant denying he was there, an eyewitness identification expert's testimony on reliability problems with eyewitness identification, and expert testimony on a blood test of the defendant's shoe. The circuit court found the codefendant not credible and the remaining evidence unlikely to change the result. The appellate court affirmed. Defendant appealed, contending the circuit court failed to view the evidence collectively and objectively.

The supreme court affirmed, reviewing the circuit court's determinations for manifest error. The court found the circuit court's credibility determinations were not manifestly erroneous. The codefendant's testimony in the third-stage hearing contradicted his own testimony at his own trial, where he denied being involved in the shooting or knowing who the shooter was. Likewise, the court found the eyewitness expert testimony was unlikely to change the result on retrial; the eyewitness testimony at trial was consistent, with extensive questioning and cross-examination. Finally, testimony as to the absence of a blood sample on defendant's shoe now was consistent with the testimony at trial that only an inconclusive preliminary sample was done, due to the low amount available for testing.

Justice Holder White delivered the judgment of the court, with opinion.