Sampler of Illinois recantation cases in which

People v. Marquis has been cited in denying relief

Compiled by Injustice Watch from Lexis
People v. Newkirk, 2012 IL App. LEXIS 2963 (Ill. App. Ct. 2nd Dist. 2012, unreported
under Supreme Court Rule 23): [A] jurys guilty verdict warrants the presumption that a
witnesss trial testimony was truthful.
People v. Cox, 2011 Ill. App. LEXIS 2186 (Ill. App. Ct. 2nd Dist. 2011, unreported under
Supreme Court Rule 23): [R]ecantation evidence is considered very unreliable.
People v. Beard, 356 Ill. App. 3d 236, 245-46 (Ill. App. Ct. 4th Dist. 2005, directly quoting
Marquis): Recanting testimony is regarded as very unreliable, and a court will usually
deny a new trial based on that ground where it is not satisfied that such testimony is true.
People v. Dempsey, 242 Ill. App. 3d 568, 586 (Ill. App. Ct. 5th Dist. 1993): It has long
been recognized that evidence of recantation is inherently unreliable and insufficient to
warrant a new trial.
People v. Steidl, 142 Ill. 2d 204, 254 (Ill. Sup. Ct. 1991) (directly quoting Marquis): Those
experienced in the administration of criminal law well know the untrustworthy character
of recanting testimony.
People v. Fields, 135 Ill. 2d 18, 43 (Ill. Sup. Ct. 1990): It is well settled that recantation of
trial testimony is generally regarded as unreliable.
People v. Bushey, 170 Ill. App. 3d 285, 289 (Ill. App. Ct. 2d Dist. 1988): It is well
established that recantation testimony is not ordinarily a sufficient basis for a new trial.
People v. Dotson, 163 Ill. App. 3d 419, 425 (Ill. App. Ct. 1st Dist. 1987): The trial court
noted [in denying relief based on the victims recantation] that there was a lack of
sufficient corroboration of this recantation, whereas the original trial testimony had more
than sufficient corroboration.
People v. Ellison, 89 Ill. App. 3d 1, 9 (Ill. App. Ct. 5th Dist. 1980): It is well-settled that
recanting testimony is regarded as very unreliable, especially where the recantation
includes a question of perjury.
People v. Veal, 58 Ill. App. 3d 938, 988-9 (Ill. App. Ct. 1st Dist. 1978): It is well settled
that recanting testimony is regarded as very unreliable, especially where the recantation
includes a question of perjury.
People v. Smith, 59 Ill. App. 3d 480, 492 (Ill. App. Ct. 4th Dist. 1978): Applications for
new trials based upon newly discovered evidence must be cautiously considered [citation
omitted], especially when the new evidence involves a confession of perjury.
People v. Lawson, 65 Ill. App. 3d 755, 756 (Ill. App. Ct. 3rd Dist. 1978): [W]itnesses
who recant their testimony have been labeled as unreliable and suspicious . . .

People v. Horobecki, 48 Ill. App. 3d 598, 602 (Ill. App. Ct. 1st Dist. 1977): Witnesses who
recant their testimony after trial have been regarded as very unreliable.
People v. Bickham, 23 Ill. App. 3d 1074, 1078 (Ill. App. Ct. 1st Dist. 1974): Recanting
testimony is regarded as very unreliable, especially where the recantation involves a
confession of perjury.
People v. Nash, 36 Ill. 2d 275, 284 (Ill. Sup. Ct. 1966) (directly quoting Marquis):
Recanting testimony is regarded as very unreliable, and a court will usually deny a new
trial based on that ground where it is not satisfied that such testimony is true.