Appealability of Orders Granting New Trials in Postconviction Proceedings

Introduction

The Supreme Court of Illinois decided People v. Harris (2025 IL 130351) on April 24, 2025. Ralph Harris had been convicted of multiple serious felonies—two 1992 murders and attempted armed robberies (the “Ford” and “Patterson” cases) and a 1995 aggravated criminal sexual assault and armed robbery (the “R.T.” case). After his convictions were affirmed on direct appeal, Harris filed postconviction petitions under the Illinois Post-Conviction Hearing Act (725 ILCS 5/122-1 et seq.). He alleged that newly discovered evidence of systematic police coercion at Chicago Police Department Area 2 detectives’ station corroborated his earlier claim that his pretrial confessions were involuntary and therefore violated his Fifth Amendment and due process rights.

Following a third-stage evidentiary hearing, the circuit court denied relief. The First District Appellate Court in People v. Harris, 2021 IL App (1st) 182172 (“Harris I”), reversed and remanded for a new suppression hearing. On remand a different judge denied Harris’s motion to suppress but—despite finding the confessions voluntary—vacated the convictions and ordered new trials on the ground that jurors might weigh the confessions differently in light of the newly discovered pattern-and-practice evidence. The State appealed. In a divided decision, the appellate court in People v. Harris, 2023 IL App (1st) 221033 (“Harris II”), held that it lacked jurisdiction because the order granting new trials was not a final order or an authorized interlocutory order under Supreme Court Rule 604(a).

The Supreme Court granted the State leave to appeal. It held that the circuit court’s postconviction order granting new trials is a final judgment from which the State may appeal under article VI, section 6 of the Illinois Constitution, section 122-7 of the Post-Conviction Act, and Rule 651(a). The Court reversed Harris II and remanded for consideration of the merits of the State’s appeal.

Summary of the Judgment

The principal issue was whether an order vacating convictions and granting new trials after postconviction proceedings is a final order from which the State may appeal.
The Supreme Court held that such an order is indeed a final judgment arising from postconviction relief.
It explained that the Post-Conviction Hearing Act contemplates appeals from any final postconviction judgment (725 ILCS 5/122-7; Ill. S. Ct. R. 651(a)).
It rejected Harris’s argument that the First District’s mandate in Harris I implicitly vacated his convictions and foreclosed further postconviction proceedings; instead, Harris I simply reversed the denial of relief and remanded for additional proceedings on the same coercion claim.
The Court reversed the appellate court’s dismissal for lack of jurisdiction and remanded the matter for a merits adjudication of the State’s appeal.

Analysis

Precedents Cited

Illinois Constitution, art. VI, § 6: Gives appellate courts jurisdiction over “final judgments” of the circuit court.
Post-Conviction Hearing Act, 725 ILCS 5/122-7: Provides that “any final judgment entered upon [a postconviction] petition shall be reviewed in a manner pursuant to the rules of the Supreme Court.”
Supreme Court Rule 651(a) (eff. July 1, 2017): Allows an appeal “from a final judgment of the circuit court in any postconviction proceeding.”
People v. Joyce, 1 Ill. 2d 225 (1953): Firmly establishes that the State may appeal orders granting new trials in postconviction proceedings.
People v. Scott, 194 Ill. 2d 268 (2000): Applies Joyce to sentences, confirming the State’s right to appeal from postconviction orders granting a new sentencing hearing.

Legal Reasoning

The Court’s reasoning unfolded in three major steps:

Characterization of the Circuit Court Order: The order vacating Harris’s convictions and granting new trials was entered after a full postconviction adjudication on the merits of his coerced-confession claim. As such, it was a final disposition of Harris’s petition under the Act.
Scope of State’s Appeal Rights: Under article VI, section 6 and Rule 651(a), the State may appeal “any final judgment” in a postconviction case. The Court reaffirmed that an order granting postconviction relief—including vacating convictions and ordering new trials—is final and appealable.
Mandate and Continuation of Postconviction Proceedings: The First District’s mandate in Harris I simply reversed the denial of relief and remanded for further proceedings on the same claim. It did not itself vacate the convictions. The subsequent circuit court proceedings were a continuation of Harris’s postconviction petition, culminating in a new, final order. Thus the appellate court erred in treating the appeal as an unauthorized interlocutory appeal.

Impact

This decision clarifies and stabilizes postconviction procedure and appellate jurisdiction in Illinois:

It confirms that any circuit court order granting a new trial—whether on direct motion or in postconviction—constitutes a final judgment for appeal purposes.
It prevents confusion arising from remands for “new suppression hearings” by reaffirming the three-stage structure of the Post-Conviction Act and rejecting any de facto “fourth stage.”
It reinforces the State’s right to challenge adverse postconviction outcomes at the appellate level, safeguarding victims’ and society’s interests in finality and fairness.

Complex Concepts Simplified

Final Judgment: A court’s decision that ends litigation on the merits and leaves nothing to be done but enforce or execute the judgment. Here it is the order granting a new trial.
Interlocutory Order: A ruling made during the course of litigation that does not finally determine the entire controversy. The State’s appeal did not rest on an interlocutory ground.
Post-Conviction Stages:
1. Stage 1: Clerk’s review—petition is dismissed if patently meritless.
2. Stage 2: Pleading stage—petition is advanced if it makes a “substantial showing” of constitutional deprivation.
3. Stage 3: Evidentiary hearing—circuit court determines by a preponderance of the evidence whether the petitioner is entitled to relief (new hearing or new trial).
Mandate Rule: When an appellate court issues its mandate, the circuit court must comply precisely with its directions. Harris I’s mandate reversed the denial of postconviction relief and remanded for further proceedings—it did not itself grant relief.

Conclusion

People v. Harris (2025 IL 130351) establishes that an order vacating convictions and granting new trials as the result of postconviction proceedings is a final, appealable judgment from which the State may appeal under article VI, section 6 and Rule 651(a). The Supreme Court reversed the appellate court’s dismissal for lack of jurisdiction, reaffirming the three-stage structure of the Post-Conviction Hearing Act and the State’s right to pursue appellate review of adverse postconviction rulings. This decision ensures clarity and uniformity in postconviction litigation and appellate practice in Illinois.