Darnell Dixon v. Tarry Williams
93 F.4th 394 · Court of Appeals for the Seventh Circuit · 2024
Facts
Darnell Dixon was convicted of home invasion and murder, largely based on an unsigned confession. Years later, in federal habeas proceedings, Dixon presented new evidence: the state's appellate brief contradicted its trial theory of accomplice liability by stating the alleged accomplice had no involvement, and the detective who took Dixon's confession had a documented history of torturing suspects and perjury.
Issue
Did the district court err in denying federal habeas relief to Dixon, who claimed actual innocence and prosecutorial misconduct based on newly discovered evidence regarding police coercion and the state's shifting stance on an accomplice's involvement?
Holding
The Seventh Circuit affirmed the district court's denial of habeas relief. The court found that Dixon's new evidence did not meet the "extremely high standard" for substantive actual innocence, nor did the state's contradictory statements, while deemed "incompetence or malpractice," constitute prosecutorial misconduct warranting relief.
Rule
To establish actual innocence as a gateway to habeas review, a petitioner must show it is "more likely than not that no reasonable juror would have convicted him in the light of the new evidence." A freestanding actual innocence claim, if recognized, would require an even higher standard of "unquestionably establish[ing]" innocence. Prosecutorial misconduct requires proving the testimony was false and prosecutors knew it.
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