People v. Muhammad

Summary

The Illinois Supreme Court held that Muhammad's alleged statements fall within the Torture Inquiry and Relief Commission Act's broad definition of a tortured confession, even though Muhammad denied making them, and therefore judicial review and an evidentiary hearing were warranted. The court further held that an alleged Brady violation may be considered as part of the totality of the circumstances bearing on torture, but is not a freestanding claim under the Act. The court reversed the appellate court's removal of the special prosecutor because Muhammad did not present sufficient evidence of an actual conflict of interest.