People v. Flournoy

Summary

The Illinois Supreme Court affirmed the denial of leave to file a successive postconviction petition. It held that a petitioner may use the same evidence to plead actual innocence and constitutional trial-error claims, but the evidence cannot ultimately satisfy both claims because actual-innocence evidence must be genuinely new while trial-error evidence must have been available at trial. The court further held that the affidavits did not present newly discovered evidence and that the due-process and ineffective-assistance claims failed for lack of cause because substantially identical claims had been raised previously.