People v. Jackson

Summary

The Illinois Supreme Court affirmed Aaron Jackson's first degree murder conviction and 35-year sentence, holding that eyewitness identifications by Nortisha Ball and Gilda Lott, corroborated by fingerprint, gunshot-residue, DNA, and limp evidence, were sufficient for a rational jury to convict beyond a reasonable doubt despite recantations and inconsistencies. Two prosecutorial mischaracterizations in closing argument—that the DNA 'matched' and that a 'fresh print' was recovered—were error but isolated and not reversible, which defeated both plain-error review and a Strickland prejudice claim premised on counsel's failure to object. The court further held that the trial court did not manifestly err in denying new counsel on defendant's pro se ineffective-assistance claims because they amounted to trial strategy, and that although the State's adversarial participation in the preliminary Krankel inquiry was error, it is not structural, is amenable to harmless error review, and was harmless beyond a reasonable doubt on this record; People v. Gore was overruled to the extent it held such error can never be harmless.