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Habeas Corpus Petition- Prosecutorial Misconduct

By: WISCONSIN LAW JOURNAL STAFF//February 26, 2024//

Habeas Corpus Petition- Prosecutorial Misconduct

By: WISCONSIN LAW JOURNAL STAFF//February 26, 2024//

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7th Circuit Court of Appeals

Case Name: Darnell Dixon v. Tarry Williams

Case No.: 21-1375

Officials: Rovner, Hamilton, and Brennan, Circuit Judges.

Focus: Habeas Corpus Petition- Prosecutorial Misconduct

Darnell Dixon filed a habeas corpus petition after being found guilty of home invasion and murder by an Illinois state court and sentenced to life imprisonment. Dixon’s petition primarily centered on claims of actual innocence and prosecutorial misconduct. The Seventh Circuit upheld the denial of his habeas petition by the Northern District of Illinois.

The case stemmed from a series of events involving a drug-related robbery and subsequent murders. Dixon and Eugene Langston were implicated in the murders, with Langston being identified in a police lineup by a witness, Horace Chandler. However, Chandler later recanted this identification. The state’s case against Dixon relied on a confession that Dixon later asserted was false. Dixon’s confession and Chandler’s identification of Langston played a central role in the state’s theory of accomplice liability, contending that Dixon was responsible for Langston’s actions.

In his habeas petition, Dixon argued that he was denied due process when the trial court excluded evidence that charges against his alleged accomplice, Langston, were dismissed. He also claimed that his trial counsel was ineffective for failing to object to the exclusion of that evidence. Additionally, Dixon alleged that the state engaged in prosecutorial misconduct by presenting conflicting positions regarding Langston’s involvement in the murders at trial and during post-conviction proceedings.

However, the Seventh Circuit determined that Dixon’s claim of actual innocence, based on the state’s post-conviction assertion that Langston’s involvement was irrelevant and evidence of abusive and perjurious conduct by the case’s police detective, did not meet the stringent standard required to conclusively prove his innocence. The Seventh Circuit also dismissed Dixon’s arguments of prosecutorial misconduct and ineffective assistance of counsel, finding no clear error in the district court’s factual findings on these matters.


Decided 02/20/24

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