Sufficiency of Evidence

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7^th Circuit Court of Appeals

Case Name: Julius Evans v. Alex Jones

Case No.: 19-3466

Officials: RIPPLE, BRENNAN, and ST. EVE, Circuit Judges.

Focus: Sufficiency of Evidence

An Illinois jury convicted Julius Evans of the first-degree murder of Moatice Williams, who was killed in a drive-by shooting in Chicago. Only one eyewitness—Andrew Jeffers—connected Evans to the shooting. Jeffers’s account of the shooting dramatically changed over time. Jeffers initially only provided a few general identifying details of the shooter, and did not specifically identify any of the shooters. Eleven months later, however, the police approached him while he was incarcerated and Jeffers then identified Evans as the shooter. Then, at trial, Jeffers recanted that identification: he testified that he did not see the identity of the shooter but had identified Evans because the police told him to.

During closing arguments, the prosecutor argued that Jeffers’s trial testimony—that he did not see Evans shoot Williams—was false and the jury should disbelieve it because Jeffers only changed his story after being paid a visit by a defense investigator working for Evans’s co-defendant, Mario Young, who was a known gang member. Evans appealed his conviction, asserting that the prosecutor’s statements during closing argument deprived him of his right to a fair trial. He contended that the prosecutor’s statements were improper because there was insufficient evidence in the record to support them, and that they were prejudicial because Jeffers’s credibility was of the utmost importance given the lack of other evidence against Evans. The state appellate court concluded that there was sufficient evidence in the record to support the prosecutor’s statements during closing argument, and so they were not improper.

Evans unsuccessfully petitioned the state court for postconviction relief. He then filed a habeas petition in federal court, which the district court granted. Upon a close examination of the record and giving deference to the state appellate court’s findings, we find that the state appellate court’s determination that the prosecutor’s statements were proper was objectively unreasonable. While we “do not lightly grant petitions for a writ of habeas corpus brought by state prisoners,” Cook v. Foster, 948 F.3d 896, 899 (7th Cir. 2020), we agree with the district court that the facts of this case compel the conclusion that Evans was deprived of his right to a fair trial and he is entitled to relief. We therefore affirm.

Affirmed

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Derek A Hawkins is Associate Corporate Counsel, IP at Amazon.