People v. English

Summary

The Illinois Supreme Court affirmed the denial of Scott English's postconviction petition challenging his felony-murder conviction predicated on aggravated battery of a child. The court held the independent-felonious-purpose claim was forfeited because it could have been raised on direct appeal, and that appellate counsel was not ineffective for failing to raise it because the law at the time did not support such an argument. Justice Freeman specially concurred, arguing the claim was noncognizable under the Post-Conviction Hearing Act because Morgan's rule was statutory, not constitutional.