People v. McCoy

2025 IL App (1st) 240198-U
CourtAppellate Court of Illinois
DecidedJanuary 16, 2025
Docket1-24-0198
StatusUnpublished
Cited by1 cases

This text of 2025 IL App (1st) 240198-U (People v. McCoy) 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. McCoy, 2025 IL App (1st) 240198-U (Ill. Ct. App. 2025).

Opinion

2025 IL App (1st) 240198-U

FOURTH DIVISION Order filed: January 16, 2025

No. 1-24-0198

NOTICE: This order was filed under Supreme Court Rule 23 and is not precedent except in the limited circumstances allowed under Rule 23(e)(1). ______________________________________________________________________________

IN THE

APPELLATE COURT OF ILLINOIS

FIRST DISTRICT ______________________________________________________________________________

THE PEOPLE OF THE STATE OF ILLINOIS, ) Appeal from the ) Circuit Court of Plaintiff-Appellee, ) Cook County. ) v. ) No. 86 CR 10404 ) MICHAEL McCOY, ) Honorable ) Michael R. Clancy, Defendant-Appellant. ) Judge, presiding.

JUSTICE HOFFMAN delivered the judgment of the court. Presiding Justice Rochford and Justice Lyle concurred in the judgment.

ORDER

¶1 Held: The denial of the defendant’s postconviction petition following a third-stage evidentiary hearing is affirmed when the actual-innocence claim at issue depended on the credibility of a codefendant’s testimony, the circuit court found that the codefendant lacked credibility, and that determination was not manifestly erroneous.

¶2 Following a third-stage evidentiary hearing, appellant Michael McCoy (the defendant)

appeals the denial of his successive petition for postconviction relief filed under the Post-

Conviction Hearing Act (Act) (725 ILCS 5/122-1 et seq. (West 2018)). At issue in the hearing was No. 1-24-0198

the defendant’s claim of actual innocence, which was premised primarily on new evidence from

codefendant Wayne Millighan purportedly exonerating the defendant and identifying another man

as the true perpetrator of the crime for which the defendant was convicted. The circuit court found

Millighan’s testimony at the hearing to lack credibility and denied the defendant’s petition. We

see no error in that credibility finding and affirm the denial of the petition.

¶3 The defendant’s third-stage evidentiary hearing was held on remand from our reversal of

the second-stage dismissal of the defendant’s petition. The facts of the defendant’s case and the

postconviction petition at issue in this appeal have been adequately set forth in our opinion in that

case (People v. McCoy, 2023 IL App (1st) 220148, ¶ 9) and in our opinion affirming the

defendant’s convictions and sentences (People v. McCoy, 238 Ill. App. 3d 240 (1992)). For the

present appeal, it suffices to say that the defendant was convicted of armed robbery and first-degree

murder for robbing M&R Food and Liquor (M&R) with two other men and shooting and killing

store owner Nazih Youssef during the robbery. The evidence against the defendant consisted

primarily of the identifications of the three surviving store employees, who collectively gave police

a description of the shooter that matched the defendant. Two of the employees identified the

defendant as the shooter in a photo array, and all three identified him as the shooter in a lineup and

at his trial. In addition to that evidence, the State presented testimony that a swab of a substance

found on the defendant's shoe tested positive for the presence of blood, although there was not

enough of a sample to conduct any further testing on the substance. Testimony also established

that a shoe print that the shooter left on a door in the store did not match the tread pattern of the

defendant’s shoes.

-2- No. 1-24-0198

¶4 The defendant’s present successive postconviction petition raised four claims for relief,

only one of which remains at issue. In that claim, the defendant asserted that he was actually

innocent, citing a new affidavit from Millighan averring that Millighan was one of the robbers and

that the defendant was not. Instead, Millighan identified a man named Howard Reed as the true

shooter. The defendant also alleged in a supplemental petition that at a hypothetical new trial a

serology expert would testify that the substance on his shoe was not blood and that an expert on

eyewitness identifications would explain why the identifications made by the store employees

were of dubious credibility.

¶5 At the hearing on the defendant’s petition, Millighan testified that he was diagnosed with

Parkinson’s Disease about three years earlier, but that the disease did not affect his memory or

comprehension. Millighan admitted that he participated in the robbery of M&R along with men

named “Buck,” “Geno,” and Howard Reed. He did not know Buck’s or Geno’s last name.

According to Millighan, Reed was the one who entered the back of the store and shot Youssef.

Millighan knew the defendant and had seen him many times prior to the robbery. He testified that

the defendant was not involved in the robbery. Millighan acknowledged that he lied when he

professed innocence in his trial and in subsequent postconviction proceedings, which he explained

was motivated by a desire “to go home.”

¶6 The defendant also presented testimony from Dr. Nancy Franklin, an expert on eyewitness

identification and memory. She testified that the M&R employees’ identifications of the defendant

as the shooter “are very likely to have been produced through post-event influences and are at high

risk of being inaccurate.” She explained that this conclusion was based on the fact that the

witnesses only observed the shooter for a short amount of time; the observation occurred in the

-3- No. 1-24-0198

presence of multiple weapons during a high-stress event in which their friend had been shot; the

shooter was wearing a hat; and the shooter was of a different race. Dr. Franklin also noted that one

of the witnesses had initially failed to identify anyone from a photo array that contained the

defendant, “which would be diagnostic of innocence.” Additionally, according to Dr. Franklin, the

live lineup contained an inadequate number of suspects, and only one of those suspects, the

defendant, was wearing clothing that was similar to what the witnesses had described the shooter

as wearing, which, Dr. Franklin testified, “produces a very high risk of what's referred to as

‘clothing bias.’ ”

¶7 The defendant also presented testimony from Deanna Lankford, a forensic casework

director at Bode Technologies, which performs forensic tests and analysis for the Illinois State

Police. She testified that she had not performed any testing for the defendant’s case, but she had

reviewed reports from tests that had been conducted by others, which included the original 1986

ortho-tolidine preliminary test on the substance on the defendant’s shoe, as well as the report of a

2013 phenolphthalein (PTH) test on that same substance. She explained that the type of ortho-

tolidine test that was performed in 1986 is very sensitive and that the presence of certain fruits or

vegetables, milk, or urine can produce a false positive result. As a consequence, a positive ortho-

tolidine test would only indicate that a “particular stain is possibly indicating the presence of

blood.” According to Lankford, the testimony of the State’s serology witness at the defendant’s

trial “overstated” the import of that presumptive test; the substance should not have been referred

to as “blood,” but rather “possibly blood.” As for the 2013 PTH test, Lankford testified that it was

negative for the presumptive presence of blood, meaning that “there was no blood present or there

was not enough blood present to detect.”

-4- No.

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Related

People v. McCoy
2026 IL 131565 (Illinois Supreme Court, 2026)
People v. Carpenter
2025 IL App (4th) 241451-U (Appellate Court of Illinois, 2025)

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2025 IL App (1st) 240198-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-mccoy-illappct-2025.