People v. Kirchner

2020 IL App (4th) 180475-U
CourtAppellate Court of Illinois
DecidedJune 9, 2020
Docket4-18-0475
StatusUnpublished

This text of 2020 IL App (4th) 180475-U (People v. Kirchner) is published on Counsel Stack Legal Research, covering Appellate Court of Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
People v. Kirchner, 2020 IL App (4th) 180475-U (Ill. Ct. App. 2020).

Opinion

NOTICE 2020 IL App (4th) 180475-U Rule 23 filed June 9, 2020 This order was filed under Supreme Court Rule 23 and may not be cited NO. 4-18-0475 Modified upon denial of as precedent by any party except in Rehearing July 16, 2020 the limited circumstances allowed IN THE APPELLATE COURT under Rule 23(e)(1). OF ILLINOIS

FOURTH DISTRICT

THE PEOPLE OF THE STATE OF ILLINOIS, ) Appeal from the Plaintiff-Appellee, ) Circuit Court of v. ) Douglas County WILLIAM BRADLEY KIRCHNER, ) No. 97CF67 Defendant-Appellant. ) ) Honorable ) Roger B. Webber, ) Judge Presiding.

JUSTICE DeARMOND delivered the judgment of the court. Justices Knecht and Harris concurred in the judgment.

ORDER ¶1 Held: The appellate court affirmed, holding the defendant failed to make a substantial showing of a constitutional violation, the trial court properly denied defendant’s request for forensic testing, and postconviction counsel provided reasonable assistance.

¶2 In February 2018, the trial court granted the State’s motion to dismiss defendant

William Bradley Kirchner’s successive postconviction petition during the second stage of the

proceedings under the Post-Conviction Hearing Act (Postconviction Act) (725 ILCS 5/122-1 to

122-7) (West 2014)) and denied defendant’s request for forensic testing pursuant to section 116-

3 of the Code of Criminal Procedure of 1963 (Criminal Procedure Code) (725 ILCS 5/116-3)

(West 2014)).

¶3 On appeal, defendant’s argument is threefold: (1) the trial court erred in

dismissing his postconviction petition because he made a substantial showing he received

ineffective assistance of counsel, (2) the trial court erred in denying his request for forensic testing, and (3) postconviction counsel provided defendant unreasonable assistance. We disagree

and affirm the trial court’s judgment.

¶4 I. BACKGROUND

¶5 In June 1998, a jury convicted defendant of the August 1997 murders of Charles

Brewer, Doris Jean Brewer, and Bonnie Brewer. Our supreme court affirmed defendant’s

convictions in December 2000. People v. Kirchner, 194 Ill. 2d 502, 743 N.E.2d 94 (2000).

Meanwhile, defendant filed a pro se postconviction petition, arguing he received ineffective

assistance of trial counsel. The trial court dismissed the petition in September 2010 and this court

affirmed the decision in June 2012. People v. Kirchner, 2012 IL App (4th) 100823-U. Defendant

filed the instant petition—a successive pro se postconviction petition—in September 2015,

alleging newly discovered evidence supported his claim of actual innocence. Defendant’s

petition also included a request for forensic testing pursuant to section 116-3 of the Criminal

Procedure Code (725 ILCS 5/116-3 (West 2014)). Defendant attached to this petition several

supporting documents, including police reports he received via Freedom of Information Act

(FOIA) requests and a witness list from his appellate counsel’s file.

¶6 After the trial court took no action on defendant’s successive postconviction

petition, he moved to advance the petition to the second-stage proceedings outlined in the

Postconviction Act (725 ILCS 5/122-2.1 (West 2014)). In September 2016, the court advanced

defendant’s petition “for further consideration pursuant to 725 ILCS 5/122-4 through 122-6” and

appointed defendant counsel. New counsel filed an amended postconviction petition and request

for forensic testing in May 2017. Though not included in the common law record, postconviction

counsel and the trial court confirmed on the record that counsel filed a Rule 651(c) certificate

with the amended petition. Ill. S. Ct. R. 651(c) (eff. Feb. 6, 2013). The amended petition alleged

-2- defendant received ineffective assistance from trial and appellate counsel. For trial counsel, the

amended petition alleged counsel failed to present a defense that Darrell Brewer (who was

named as a potential suspect in multiple police reports attached to the petition) committed the

murders, not defendant. As for trial or appellate counsel (it is unclear), the amended petition

alleged counsel failed to investigate (and the State failed to disclose) whether a key State witness

received immunity in exchange for his trial testimony. Defendant’s amended petition

incorporated some of the attachments to his pro se petition, namely the police reports obtained

via FOIA requests and the witness chart from appellate counsel’s file.

¶7 Despite defendant’s failure to obtain leave from the trial court to file a successive

petition and make the necessary showings, the court considered the petition’s merits and the

State’s subsequent motion to dismiss it. The court concluded defendant’s trial counsel did not

render ineffective assistance when counsel opted against presenting a defense that Darrell

Brewer committed the murders. The court noted the “[defendant] has provided no affidavits or

any other evidence suggesting that there is any actual evidence of [Brewer’s] guilt.” Even with

the police reports mentioning Brewer and detailing the police investigation of Brewer, the court

determined “there [wa]s absolutely nothing to suggest that counsel was ineffective for failing to

follow-up on this theory or that [defendant] was prejudiced thereby.” The trial court next

concluded defendant’s appellate counsel did not render ineffective assistance for failing to

investigate whether a State witness received immunity. The court reasoned that since there was

“no evidence that an immunity agreement in fact had been made,” appellate counsel was not

ineffective for failing “to investigate and prove a non-existent agreement.”

¶8 The trial court then considered defendant’s request for forensic testing and found

it “[could] not determine *** the requested testing ha[d] the scientific potential to produce new,

-3- non-cumulative evidence materially relevant to defendant’s assertion of actual innocence.” The

court, therefore, denied defendant’s request since it did not meet the statutory requirements for

testing outlined in the Criminal Procedure Code. See 725 ILCS 5/116-3 (West 2014).

¶9 This appealed followed.

¶ 10 II. ANALYSIS

¶ 11 Defendant challenges the trial court’s order on three grounds. First, he argues the

trial court erred in dismissing his amended postconviction petition because he made the requisite

showing to survive a motion dismiss, i.e., he made a substantial showing of two constitutional

violations—ineffective assistance of counsel and a Brady violation. Second, he argues the trial

court erred in denying his request for forensic testing since the testing would yield new, non-

cumulative evidence supporting his actual innocence. Third, he argues postconviction counsel

provided unreasonable assistance. Taking each argument in turn, we disagree and affirm the trial

court’s order.

¶ 12 A. Dismissal of Defendant’s Postconviction Petition

¶ 13 To survive a motion to dismiss from the State at the second stage of

postconviction proceedings and advance to a third-stage evidentiary hearing, the defendant’s

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2020 IL App (4th) 180475-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-kirchner-illappct-2020.