The Illinois Appellate Roundup, Episode 2 — Three Supreme Court Rulings on Deferring to the Trial

Educational and informational only — not legal advice.

People v. Johnson (2026 IL 131337) — sufficiency of the evidence and eyewitness identification. On a sufficiency-of-the-evidence challenge, the appellate court used the wrong standard, relied on eyewitness-reliability research that was never in the trial record, and used the jury's split verdict to discredit the identifications. The Supreme Court reversed and remanded. The takeaway: sufficiency review is a narrow lane — view the evidence in the light most favorable to the State, don't reweigh credibility, don't import studies the jury never heard, and don't use an acquittal on one count to unravel a conviction on another.

People v. Shepherd (2026 IL 131240) — solicitation of murder for hire. The Court held that the offense reaches a one-sided, unilateral arrangement: a defendant is guilty even if the person he tried to hire never intended to follow through, because liability falls on the one who pays or promises to pay. The takeaway: don't rest a "for hire" defense on the hired person's lack of intent — the informant who only plays along does not break the offense.

People v. McCoy (2026 IL 131565) — successive post-conviction and actual innocence. To win on actual innocence, new evidence must be conclusive — strong enough to probably change the result on retrial. Expert testimony attacking eyewitness reliability is, in substance, impeachment, and rarely enough by itself. Denial of relief affirmed. The takeaway: actual-innocence claims live and die on the conclusive-character element; evidence that merely reopens an old argument about the State's witnesses will almost never be enough.

Every case is sourced and verified against the published Illinois opinions.

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