Patterson v. Adkins

Defendant was found guilty of first-degree murder, arson, and felony concealment of a homicide and was sentenced to 55 years in prison. The Illinois State Supreme Court affirmed his convictions on direct appeal and defendant sought federal habeas review. The habeas petition was filed outside the one-year limitation period and defendant attempted to overcome that deficiency by invoking the exception for claims of actual innocence. The district court rejected his claim and dismissed the petition as untimely. The Seventh Circuit affirmed, noting that defendant’s petition was more than six years too late and that his claim of actual innocence fell “far short” of the necessary showing to qualify for the exception. (KIRSCH and JACKSON-AKIWUMI, concurring)