## Facts

- Jennifer Lockmiller, an Illinois State University student, was found dead in her Normal, Illinois apartment on August 28, 1993, with evidence of strangulation and a stab wound.
- A clock-radio cord was wrapped around her neck; scissors were lodged in her chest; clothing and the scene suggested a sexual component; a box fan was placed across her face.
- Police recovered seven fingerprints from the clock radio: two matched Alan Beaman, four matched Lockmiller’s current boyfriend, and one remained unidentified.
- The prosecution’s theory fixed the time of death shortly after noon on August 25, 1993, and alleged the murder occurred between 12:00 p.m. and 2:00 p.m.
- Beaman, a former boyfriend living in Rockford, asserted an alibi placing him in Rockford that day; the State argued he could have made a same-day round trip to Normal during the asserted window by speeding.
- After Beaman’s conviction was affirmed on direct appeal, he filed a postconviction petition alleging constitutional violations, including suppression of evidence about a viable alternative suspect.
- Undisclosed police information indicated an alternative suspect lived near the victim, claimed a renewed relationship with her, had sold drugs to her and was owed money, had a documented history of violence toward a girlfriend, was partially uncooperative (including not completing a polygraph), and had an alibi with a gap relevant to the State’s time-of-death window.
- At trial, the defense heard little to none of that alternative-suspect information, and the defense had been limited in presenting evidence about the victim’s relationships absent a non-speculative link to the crime.

## Issues

1. Whether the State violated due process under Brady by failing to disclose favorable evidence concerning a viable alternative suspect.
2. Whether the suppressed alternative-suspect evidence was material, i.e., whether there was a reasonable probability that disclosure would have changed the trial’s outcome.

## Decision

- The Illinois Supreme Court reversed the denial of postconviction relief and remanded for a new trial.
- The court held the State suppressed favorable information about a viable alternative suspect.
- The court held the suppressed evidence was material because it undermined confidence in the verdict in a largely circumstantial case dependent on a narrow time-distance theory.

## Legal Principles

- Under Brady, due process requires disclosure of evidence favorable to the accused, including evidence that is exculpatory or impeaching.
- Brady applies when the State suppresses favorable evidence, whether intentionally or inadvertently.
- Suppressed evidence is material if there is a reasonable probability that, had it been disclosed, the result of the proceeding would have been different; materiality is assessed in light of the entire record and whether nondisclosure undermines confidence in the verdict.
- Evidence pointing to a viable alternative perpetrator can be Brady material, particularly where it would support a non-speculative third-party culpability theory and affect the admissibility and presentation of the defense.

## Conclusion

The court concluded that withholding police information identifying and detailing a viable alternative suspect deprived Beaman of a fair trial under Brady, and it ordered a new trial because the nondisclosure created a reasonable probability of a different outcome in a circumstantial prosecution.


People v. Beaman, 890 N.E.2d 500 (Ill. 2008)