## Facts

- Ramon Nelson was killed in Markham, Illinois, after being struck in the head with a wooden stick or bat while riding his bicycle away from a liquor store.
- Lawrence Owens was convicted of first-degree murder after a bench trial in the Circuit Court of Cook County and sentenced to 25 years’ imprisonment.
- The prosecution’s case relied primarily on two eyewitnesses, Maurice Johnnie and William Evans.
- Johnnie identified Owens from a six-person photo array and later in a lineup; Owens was the only person who appeared in both the photo array and the lineup.
- Evans’s identifications were inconsistent; at trial he twice pointed to someone other than Owens from the photo array when asked to identify the assailant, and his account conflicted with Johnnie’s on key details.
- No physical or forensic evidence linked Owens to the crime.
- The trial judge stated the “real issue” was that Owens knew Nelson was a drug dealer and killed him for that reason, and concluded the State had proven that point even though the record contained no evidence that Owens knew Nelson or had a drug-related motive.

## Issues

1. Whether a bench-trial conviction violates the Fourteenth Amendment’s Due Process Clause when the trial judge’s finding of guilt rests in part on facts not introduced in evidence.
2. Whether the state courts unreasonably applied clearly established Supreme Court law, for purposes of 28 U.S.C. § 2254(d), by treating the trial judge’s reliance on non-record facts as harmless.

## Decision

- The Seventh Circuit reversed the district court’s denial of habeas relief on the due process claim.
- The court held that the trial judge based the guilt determination in part on a motive theory unsupported by any evidence in the trial record, violating due process.
- The court concluded the state courts’ approval of the conviction (including any harmless-error rationale) was an unreasonable application of clearly established Supreme Court precedent requiring guilt to be determined solely from the evidence introduced at trial.
- The court granted the writ of habeas corpus and ordered the State to retry Owens within 120 days or release him.

## Legal Principles

- Due process requires that guilt or innocence be determined solely on the basis of evidence introduced at trial; a conviction may not rest on conjecture or extrajudicial “facts.”
- In a bench trial, a judge’s explicit reliance on non-record facts that supply a missing element (such as motive) can constitute a constitutional violation.
- Under AEDPA, federal habeas relief is available when the state court decision is contrary to, or an unreasonable application of, clearly established Supreme Court law, or rests on an unreasonable view of the facts in light of the record.

## Conclusion

The Seventh Circuit held that Owens’s bench-trial murder conviction violated due process because the trial judge relied on a drug-motive theory absent from the evidentiary record, and it granted § 2254 relief requiring the State to retry Owens within 120 days or release him.


Owens v. Duncan, 781 F.3d 360 (7th Cir. 2015)