“I didn’t commit the crime. My hope is that sooner rather than later, the truth will come out and I’ll be vindicated. I want justice not just for myself and my family, but for Bill Little.”
~ Jamie Snow, Pantagraph Interview
THANK YOU TO THOSE WHO HAVE COME FORWARD! YOU ARE NOT ALONE! It is NEVER too late to do the RIGHT thing!!
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Jamie Snow's Attorneys' Performance Violated His Constitutional Right to Counsel
These claims of ineffectiveness are supported by the documents included in Group
Exhibit 29, which show that Frank Picl, who because of health issues for G. Frank Riley, had major
responsibility over Jamie Snow's trial, developed a repeating pattern of misconduct in other cases
around this same time, and was shortly thereafter disbarred for major misconduct.
To show ineffective assistance of counsel, a defendant must demonstrate that
counsel's performance fell below an objective standard of reasonableness and that there is a
reasonable probability that the result of the proceedings would have been different absent counsel's
errors. Strickland, 466 U.S.at 687;People v. Weir,111 Ill.2d 334,337,490 N.E.2d 1,2 (1986).
Here, counsel's performance fell far below that threshold in numerous ways.
put, Jamie Snow's counsel could have investigated and presented evidence that would have exposed
some of the misconduct in this case, challenged improper evidence, and effectively impeached
questionable witnesses presented by the state. They inexpiicably failed to do so. In the face of his
counsel's ineffectiveiness, he had no opportunity to combat the state's weak evidence.
Some of the evidence that Mr. Snow presents in this petition in support of his other
claims is evidence that he gleaned from reviewing the discovery in this case, and from speaking with
known witnesses. In some instances, this is information that his trial counsel, had they conducted
meaningful investigation into his case, might have obtained and should have used to support Mr.
- Counsel failed to use Jeffery Pelo' s interview transcript, the police reports concerning
Danny Martinez, and testimony from Dennis Hendricks and William Hendricks as guides to elicit
testimony from Pelo and to discredit Martinez's testimony about what happened in front of the gas
station. (Exs. 1, 5 &7.)
- Counsel failed to subpoena the police radio tapes, which support Pelo's version of
events and which, considered with Pelo and Williams' testimony, establish that Martnez's testimony
is incredible. (Exs. 1,2,5, & 6)
- Counsel failed to call Thomas Sanders, whose testimony was readily available from
Susan Claycomb's trial, to demonstrate that Carlos Luna's "identification" of Jamie Snow was
completely weak. (Ex. 8.)
- Counsel failed to speak to Steve Scheel, who told Larry Biela that had counsel spoken
to him in advance, would have exposed the reasons for his testimony. (Ex. 15, Biela Aff. at 20.)
- Given the information in the police reports concerning how Danny Martinez finally
came to identify Jamie Snow, counsel was ineffective for failing to file a motion to suppress arguing
that his identification was unreliable and the product of inherently suggestive tactics.
- Counsel failed to investigate the report from Randall Howard that someone on the
jury knew Jamie Snow and had a reason to have animus against him. (Ex. 13, at 12-55.)
- Counsel failed to investigate Karen Strong's reasons for providing false testimony
against Jamie Snow.
- Counsel failed to investigate available evidence that witnesses in this case received
deals in exchange for their testimony, and to use that evidence to impeach those witnesses. Counsel
further failed to ask for and develop evidence that would impeach witnesses who claimed Jamie
Snow confessed to them while they were incarcerated together.
- Counsel failed to investigate and present evidence that Dawn Roberts' testimony
about toasts was flawed, and that the only toasting Jamie Snow did to any "Billy"
was a respectful
toasting for Tina Mcwhorter's brother Billy who had died shortly before.
- Counsel failed to use the testimony of Charlie Crowe to impeach Martinez by
exposing how many other people he'd identified for this crime, and clearly explaining that when
given the perfect opporfunity to identify Mr. Snow as the person he claimed he saw, he was unable
to do so.
- Counsel failed to expose evidence that the victim's mother had been contacting the
key witness in this case, Danny Martinez, possibly at the behest, direction, or with the consent of the
Bioomington Police Department.
- Counsel failed to use availabie discovery to impeach testimony by Detectives Thomas
and Bemardini who falsely implied at Jamie's trial that he had admitted some involvement in this
- Counsel failed to investigate and present evidence from Darren Smart impeaching
Mary Jane Burns.
Finally, to the extent any of the new evidence included in this petition was known or
could have been known to counsel, then counsel was ineffective for failing to use it, because such
evidence supports Jamie Snow's innocence.